ML20078S571

Proposed Tech Specs Re Definition of Lco,Per GL 87-09

ML20078S571
Person / Time
Site:	Cooper
Issue date:	12/22/1994
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20078S568	List: ML20078S564 ML20078S571
References
GL-87-09, GL-87-9, NUDOCS 9412280398
Download: ML20078S571 (10)

Text

, NLS940089 Attachment Page 1 of 5 REVISED TECHNICAL SPECIFICATIONS Exigent Amendment Request Proposed Change No. 148 DEFINITION OF LIMITING CONDITIONS FOR OPERATION (LCO)

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INTRODUCTION:

As discussed below, the Nebraska Public Power District (NPPD) hereby requests that the Cooper Nuclear Station (CNS) Technical Specifications (TS) be revised, as proposed herein. The proposed change will revise specification 1.0 J, definition of LIMITING CONDITIONS for OPERATION (LCO). The proposed change to the CNS TS will make the definition of LCO consistent with the guidance provided in NRC Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications on the Applicability of Limiting Conditions for Operation and Surveillance Requirements,"

dated June 4, 1987. The proposed change is a Line Item Technical Specifications Improvement and will make the wording of CNS TS definition 1.0.J, concerning entering an operational condition consistent with the wording proposed in NRC Generic Letter 87-09.

DISCUSSION:

The proposed change is the direct result of Generic Letter 87-09, which was issued June 4, 1987. The Generic Letter and, consequently, this proposed change is intended to address the specific problem relative to the applicability of LCOs. This problem, as it applies to the CNS TS, is discussed below.

The existing CNS TS Definition 1.0.J, implies, that entry into an operational condition or change in mode is not allowed with reliance upon an LCO Action Statement, even though the Action Requirements may permit continued operation of the plant for an unlimited period of time. In the case of CNS TS, the situation is even more unclear due to the fact that some individual specifications contain provisions that entry into an operational condition is allowed provided the requirements of the Action statement are satisfied. However, the application of such exceptions has been neither consistent nor well documented.

The CNS TS Definition 1.0.J, unduly restricts plant operations when conformance to Action Requirements provides an acceptable level of safety for continued operation. Entcy into an operational condition or other specified conditions while in a LCO should be permitted if the Action Requirement for the LCO permits continued operation for an unlimited period of time.

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'. NLS940089 Attachment Page 2 of 5 This is consistent with the NRC's regulatory requirements for a LCO stated in 10 CFR 50.36 (c) (2) , and Generic Letter 87-09.

The restriction on an operational condition or other specified condition should apply only when the LCO Action Requirements establish a specific time interval a which the LCO must be cleared and a shutdown of the facility is required to conform to the action statement. Consequently, a revision to the CNS TS Definition 1.0.J, is requested to only allow entry into an operational condition in accordance with action requirements when conformance to them permits operation for an unlimited period of time.

The CNS TS definition 1.0.J, is being clarified to explicitly state that entry into an Operation condition is not permitted if the conditions for an LCO are not met and the associated action requires a shutdown.

The current CNS TS LCOs that have an unlimited period of time ascociated with them provide an adequate level of safety. ,

These LCOs ensure that the remedial actions taken in support of the LCO action requirements provide and maintain an acceptable level of safety for continued facility operation er a change in an operational condition when relief from definition 1.0.J is deemed appropriate.

Additionally, procedure 2.1.1 "Startup Procedure," 2.1.1.1

" Plant Startup Review and Authorization," and 2.1.1.2 " Technical Specifications Pre-startup Check" provide assurance that systems and components necessary for plant startup are operable. The use of these procedures provides assurance that the use of the relief allowed by the definition of an LCO establirhed with this proposed change will be limited.

The changes in wording are consistent with the guic'.9bce provided in Generic Letter 87-09. The changes in the Bases ctction as described in Generic Letter 87-09, do not apply to the CUS TS since the Definition section of the CNS custom TS does not have an associated Bases section.

DESCRIPTION OF CHANGES:

The NPPD requests that the wording of the CNS TS Definition 1.0.J, "Limi*.;ng Conditions for Operation," concerning entering an operatio al condition, be revised to be consistent with the guidance provided in NRC Generic Letter 87-09. A mark-up of the  :

affected CNS TS page is provided in Appendix A, and the new l affected CNS TS page is provided in Appendix B. The specific  ;

change proposed to the CNS TS Definition 1.0.J, is detailed below:

NLS940089 Attachment Page 3 of 5 Page 3 - Revise Specification 1.0.J, by removing the fifth paragraph of this specification in its entirety and replace it with the following: " Entry into an operational condition or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated action requires a shutdown if they are not met within a specified time interval. Entry into an operational condition or other specified condition may be made in accordance with the action requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to operational conditions as required to comply with action requirements. Exceptions to these requirements .

are stated in the individual Specifications. This specification is not applicable in the cold condition or the refueling mode."

SIGNIFICANT HAZARDS DETERMINATION:

10 CFR 50. 91 (a) (1) , requires that licensee requests for operating license amendments be accompanied by an evaluation of significant hazards posed by the issuance of the amendment. NPPD has reviewed the proposed change in accordance with 10CFR50.92 and concludes that the change does not involve a significant hazards consideration (SHC). The basis for this conclusion is that the three criteria of 10CFR50. 92 (c) are not compromised. The proposed change does not involve a SHC because the change would not:

1. Involve a significant increase in the probability or consequences of an accident previously analyzed.

The proposv <hange does not affect plant operation or the design. The snange provides specific applicability requirements to the Limiting conditions for Operation (LCO).

The proposed change incorporates only those applicability requirements and exceptions denoted by Generic Letter 87-09, concerning entering an operational condition. Invoking the proposed change in LCO definition does not impact nor alter any LCO Action Requirements in the Technical Specifications.

Those LCO Action Statements which do not require shutdown -

provide acceptable compensatory safety measures for the affected function, and therefore, operational conditions need not he restricted further. Since conformance to these LCO Actiet Requirements provide an acceptable level of safety for continued operation of the facility, entry into an operational condition or other specified conditions would not increase the probability or consequences of an accident as long as the remedial Action Requirements are met.

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Farthermore, the proposed change does not affect any accident or safety analysis event initiator as analyzed in the Updated safety Analysis Report (USAR), nor involve any modification to equipment. The proposed change is administrative in nature and primarily serves to provide plant personnel with clear guidance regarding compliance with LCOs ant Action Requirements under all operating conditions. Therefore, no significant increase in the probability or consequences of an accident previously analyzed would occur.

2. Create the possibility of a new or different kind of accident from any previously analyzed.

The proposed change does not affect any equipment design or configuration, nor does the change introduce a new mode of operation therefore, no new or different type of failures are created. The proposed change serves to strengthen the existing Cooper Nuclear Station (CNS)

Technical Specifications (TS) requirements by eliminating some areas of confusion and interpretation, and providing a clear statement of the specification's (1.0 J) intent. The proposed change will ensure that appropriate administrative requirements are invoked prior to any change in an l operational condition.

The proposed change does not affect the testing methodology for any systems. There will be no change in the j types or increase in the amount of effluents released l offsite. Since there are no changes to the function, I operation, or surveillance test methodology of any system, l equipment, or component, the possibility of a new or different kind of accident is not created.

3. Involve a significant reduction in the margin of safety.

The proposed change does not reduce the margin of safety because it has no impact on any safety analysis assumption. The proposed change clarifies the LCO definition concerning entry into an operational condition.

The proposed change ensures that the appropriate administrative requirements are met prior to any change in an operational condition. The proposed change serves to strengthen the philosophy of compliance with the Technical Specifications. The change is administrative in nature and provides explanatory information which does not impact any safety analysis. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

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', NLS940089 Attachment Page 5 of 5 ADDITIONAL basis FOR NO SIGNIFICANT HAZARDS DETERMINATION:

The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (51FR7744). The examples include: (vii) A change to conform a license to changes in regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations.

Implementation of this change to the CNS TS Definition of Limiting Conditions for Operation is consistent with the guidance provided by the NRC in Generic Letter 87-09. The NRC staff encourages licenstes to implement these technical specification ,

changes since they have concluded that this will result in improved Technical Specifications for all plants.

CONCLUSION:

The NPPD has evaluated the proposed change described above against the criteria of 10CFR50.92 (c) in accordance with the requirements of 10CFR50. 91(a) (1) . This evaluation has determined that Proposed Change No. 148 to the CNS TS 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 different kind of accident from any accident previously evaluated; or 3) create a significant reduction in the margin of safety. Therefore, the NPPD requests NRC approval of proposed change No. 148 to the CNS TS.

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• Attachment to NLS940089 APPENDIX "A" l

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8. Simulated Automatic Actuation - Simulated automatic actuation means Di . applying a simulated signal to the sensor to actuate the circuit in l question.

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8.A Source Check - A SOURCE CHECK shall be the qualitative assessment of chan-nel response when the channel sensor is exposed to a source of radioactivity.

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9. Trip System - A trip system means an arrangement of instrument channel r g i trip signals and auxiliary equipment required to initiate action to accomplish a protective function. A trip system may require one or J j more instrument channel trip signals related to one or more plant I parameters in order to initiate trip system action. Initiation of protective action may require the tripping of a single trip system or the coincident tripping of two trip systems.

I J. Limiting Conditions for,9peration (LCO) - The limiting conditions for i

operation specify the minimum acceptable levels of system performance necessary to assure safe startup and operation of the facility. When

< these conditions are met, the plant can be operated safely and abnormal situations can be safely controlled.

d Limiting Conditions for Operation (LCO) shall be applicable M l during the operational conditions specified for each specifi-I cation.

g h I Adherence to the requirements of the LCO within the specified I i time interval shall constitute compliance with the specification.

In the event the LCO is restored prior to expiration of the f

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, ( specified time interval, completion of the LCO action is not required.

i In the event an LCO cannot be satisfied because of circumstances in excess of those addree, sed in the specification, the facility shall be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDCVN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> unless corrective measures are completed that permit operation under the LCO for the specified time interval as measured from initial discovery. Exception to these requirements shall be stated in the individual specifications.

En .y e an pe ti al ond tio sha 1 n t b n.a e u le Q e nd io s of th LC are met ich ut eli nee on he cci ns sp if _d i- th LC un ss the . rise exc pte . is pr isi n a all ot .rev nt ass e rou op ra on co dit on re ire (oWhen a system, subsystem, train, component or device is determined to be inoperable l mp1' wi c sp cif >d a io of an CO l l

solely because its emergency power source is inoperable, or solely because its  !

normal power source is inoperable, it may be considered OPERABLE for the purpose of J satisfying the requirements of its applicable Limiting Condition for Operation, l provided: (1) its corresponding normal or emergency power source is OPERABLE; and 1 (2) all of its redundant system (s), subsystem (s), train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the requirements of this specification. I Unless both conditions (1) and (2) are satisfied, the unit shall be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This specification is not applicable in the cold condition or the refueling mode.

K. Limiting Safety System Setting (LSSS) - The limiting safety system settings are settings on instrumentation which initiate the automatic protective action at a level such that the safety limits will not be exceeded. The region between the safety limit and these settings represent a margin with normal operation lying below these settings. The margin has been established so that with proper operation of the instrumentation the safety limits will never be exceeded. ,

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I Entry into an operational condition or other specified condition shall not be made when the conditione for the Limiting Conditions for Operation are not met and the associated action requires a shutdown if they are not met within a specified time interval.

Entry into an operational condition or other specified condition may be made in accordance with the action requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to operational conditions as required to comply with action requirements. Exceptions to these requirements are s' ated in individual Specifications. This specification is not applicable in the cold condition or the refueling mode.

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httachment to NLS940089 l

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1 APPENDIX "B" l l

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8. Simulated Automatic Actuation - Simulated automatic actuation means applying a simulated signal to the sensor to actuate the circuit in question.

8.A gource Chech - A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a source of radioactivity.

9. Trio System - A trip system means an arrangement of instrument channel trip signals and auxiliary equipment required to initiate action to accomplish a protective function. A trip system may require one or more instrument channel trip signals related to one or more plant parameters in order to initiate trip system action.

Initiation of protective action may require the tripping of a single trip system or the coincident tripping of two trip systems.

J. Limitina Conditions for Ooeration (LCO) - The limiting conditions for operation specify the minimum acceptable levels of system performance necessary to assure safe startup and operation of the facility. When these conditiona are met, the plant can be operated safely and abnormal situations can be safely controlled.

Limiting Conditions for Operation (LCO) shall be applicable during the operational conditions specified for each specification.

Adherence to the requirements of the LCO within the specified time interval shall constitute compliance with the specification. In the event the LCO is restored prior to expiration of the specified time interval, completion of the LCO action is not required.

In the event an LCO cannot be satisfied because of circumstances in excess of those addressed in the specification, the facility shall be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> unless corrective measures are completed that permit operation under the LCO for the specified time interval as measured from initial discovery. Exception to these requirements shall be stated in the individual specifications.

Entry into an operational condition or other specified condition shall not be made when the conditions for the Limiting conditions for Operation are not met and the associated action requires a shutdown if they are not met within a specified time interval. Entry into an operational condition or other specified condition may be made in accordance with the action requirements when conformance to them permits continued operation of the facility for an unlimited period cf time. This provision shall not prevent passage through or to operational conditions as required to comply with action requirements. Exceptions to these requirements are stated in the individual Specifications. This specification is not applicable in the cold condition or the refueling mode.

When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system (s), subsystem (s), train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the requirements of this specification.

Unless both conditions (1) and (2) are satisfied, the unit shall be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This specification is not applicable in the cold condition or the refueling mode.  ;

K. Limitino Safety System Settina (LSSSL - The limiting safety system settings are settings on instrumentation which initiate the automatic ,

protective action at a level such that the safety limits will not be l exceeded. The region between the safety limit and these settings l represent a margin with narmal operation lying below these settings. The 1 margin has been established so that with proper operation of the i instrumentation the safety limits will never be exceeded. l l

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