ML20086B702
| ML20086B702 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/28/1995 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20086B704 | List: |
| References | |
| NLS950115, NUDOCS 9507060060 | |
| Download: ML20086B702 (11) | |
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COOPER NUCLEAR STATION P.O. BOX 98, BRoWNVILLE, NEBRA8KA 08321
. Nebraska Public Power District
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NLS950115
. June 28, 1995 U.S.
Nuclear Regulatory Commission
' Attention: Document Control Desk Washington, DC 20555
Subject:
Proposed Change No. 124 to CNS Technical Specifications Standby Liquid Control (SLC) System Cooper Nuclear Station NRC Docket No. 50-298, License No. DPR-46 Gentlemen:
In accordance with the provisions of 10 CFR 50.4 and 50.90, the Nebraska l
Public Power District (District) hereby submits a request for an amendment to 7
license DPR-46 to change the Cooper Nuclear Station (CNS) Technical Specifications. The proposed change: 1) increases the required Reactor i
Pressure Vessel (RPV) Boron concentration; and, 2) modifies the surveillance' frequency for SLC pump operability test'ag to make it consistent with the-guidelines of NRC Generic Letter 93-05.
In addition, some administrative changes are also being requested to correct typographical and editorial f
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errors.
' Attachment I contains the bases for the changes, a description of the preposed changes, the no significant hazard consideration determination, and the CNS Technical Specifications pages revised by this change. This proposed change has been reviewed by the necessary safety review committees and incorporates all amendments to the CNS Facility Operating License through.
Amendment 169 issued June 8, 1995.
To provide sufficient time for licensed operator training and the revision of station procedures, the District requests that the amendment' implementing.
these proposed changes become effective thirty days after its issuance.
The District requests that the amendment implementing these changes be issued prior to startup from the 1995 refueling outage.
5 By copy of this letter and its attachment, the appropriate State of Nebraska official is being notified in accordance with 10 CFR 50.91(b) (1).
Copies to
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the NRC Region IV Office and the CNS Besident Inspector are also being provided in accordance with 10 CFR 50.4 (b) (2).
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norrnn a0 9507060060 950628 PDR ADOCK 05000298 Ul j p
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JU.S.' Nuclear Regulatory Commission c.
June 5, 1995 Page 2 of 3 Should you have any questions or require any additional information regarding this submittal, please contact me.
sin rely, L
orn V e resident - Nuclear-GRH/GS Attachments cc:
H.
R. Borchert w/ attachments Department of Health j
State of Nebraska
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t Regional Administrator w/ attachments I
USNRC - Region IV NRC Resident Inspector w/ attachments Cooper Nuclear Station NPG Distribution w/ attachments i
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~U.S. Nuclear Regulatory Commission June 5, 1995 Page 3 of 3 STATE OF NEBRASKA)
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PLATTE COUNTY
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G.
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Horn, 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 and belief.
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Dw G.
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Horn President, Nuclear Subscribed in my presence and sworn to before me this O b day of klgt _
1995.
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to NLS950115 Page 1 of 9 COOPER NUCLEAR STATION i
TECHNICAL SPECIFICATIONS PROPOSED CHANGE NO. 124 Standby Liquid Control System Revised Pages 1
77 110 6
107 111 12 108 112 30 109 152 t
1.0.
Bases for Changes.
1.1.
The SLC system is currently designed to inject a quantity of boron solution such that a concentration of 600 ppm is reached in the Reactor Pressure Vessel (RPV) in less than 125 minutes. The concentration of 600 ppm of boron in the RPV ensures the capability of bringing the reactor from full power to a 3.0 percent Ak suberitical xenon-free cold shutdown condition (as specified in the CNS USAR, Chapter 3, Section 9.4 for Cycle 16) assuming none of the withdrawn control rods can be inserted.
However, in Service Information Letter (SIL) No. 325, June 1980, General Electric (GE) has recommended 660 ppm as the minimum bounding concentration of natural boron in the RPV for high energy 18-month cycles and/or equilibrium fuel loadings.
Therefore, to avoid having to reduce the core exposure window for future-i fuel cycles, the District proposes that this concentration be raised to 660 ppm from 600 ppm.
This change is accomplished by revising Figure 3.4.1, Sodium Pentaborate Solution Volume-Concentration Requirements. The proposed change to increase the required boron concentration in the RPV ensures that 3
a minimwm 3 percent Ak xenon free cold shutdown margin as specified for Cycle 16 will be maintained for anticipated future core reloads.
e 1.2.
NRC Generic Letter 93-051' section 4.3 recommends two changes to SLC system Technical Specifications for BWRs.
The first is that the Technical Specifications surveillance test of pumping demineralized water into the reactor pressure vessel be performed at a frequency once each refueling outage and that both SLC subsystems be tested in any two consecutive refueling outages.
CNS Technical Specifications already conform to the intent of this recommendation in surveillance requirements 4.4.A.2.c and t
4.4.A.2.d.
The second recommendation of Generic Letter 93-05 section 4.3 is that the SLC pump operability test frequency should be performed quarterly in agreement with the ASME Code.
This recommendation will be implemented by revising the surveillance frequency for testing each SLC subsystem specified in surveillance requirement 4.4.A.1 from each month to each three months.
l' Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation (Generic Letter 93-05),
i September 27, 1993.
Further information is provided in NUREG-1366, Improvements to Technical Specifications Surveillance Requirements, December 1992.
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to NLS950115 Page 2 of 9 l
This frequency of testing is consistent with ASME Code requirements, and it is sufficient to detect pump degradation.
Should any minor degradation be detected that did not immediately require repair, pump testing at more frequent intervals would be conducted.
The model specification in the l
Generic Letter includes minimum pump flow rates at a minimum required l
discharge pressure.
Surveillance requirement 4.4.A.1 will be revised consistent with the model specification by incorporating the minimum pump flow rate and discharge pressure currently specified in surveillance l
requirement 4.4.A.2.b.
l Furthermore, there has been no problem identified with respect to the I
operational performance of the SLC pumps as confirmed by the actual surveillance test data collected since 1974.
Therefore, it can be concluded that the revised pump operability specification is compatible with CNS operating experience and consistent with the guidance provided in Generic Letter 93-05.
1.3 To improve the clarity and consistency of CNS Technical Specifications for the SLC system, other administrative changes are proposed which are j
consistent with the guidance provided in Standard Technical Specifications.
These changes include the use of defined terms and the capitalization of l
defined terms.
l 1.4 Administrative changes to five other pages of CNS Technical Specifications
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have been proposed to correct typographical and editorial errors. These changes do not alter the original intent of any specification.
t 2.0.
Detailed Description of Proposed Changes.
The detailed changes discussed below are indicated in the marked-up CNS l
Technical Specifications pages attached in Appendix A and in the revised i
pages attached in Appendix B.
The abbreviation "SLC" is used and all defined terms are capitalized on the changed pages of this submittal.
2.1.
The District requests that the following changes be made to the LCO and surveillance requirements on page 107 of CNS Technical Specifications.
2.1.1.
The term " availability" is replaced with " OPERABILITY" or
" operation" as applicable.
2.1.2.
On page 107, LCO 3.4.A, Normal System Operation, is renumbered as 3.4.A.I.
2.1.3.
The frequency of surveillance requirement 4.4.A.1 is revised per Generic Letter 93-05 to a three month periodicity as follows:
t "At least once each 3 months each subsystem of the SLC system shall be tested for OPERABILITY by recirculating demineralized water to the test tank and verifying each pump develops a flow rate 2 38.2 gpm at a discharge pressure 2 1300 psig."
2.1.4.
As an editorial change, one sentence in surveillance requirement
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4.4.A.2.b is revised consistent with the wording of surveillance requirement 4.4.A.1 above.
2.1.5.
All of surveillance requirement 4.4. A.2.c is moved to page 108 for.
i improved readability.
-I 2.2.
The District requests the following changes be made to page 108:
2.2.1.
In surveillance requirement 4.4.A.2.c, for consistency the word l
" loop" is replaced by " subsystem."
2.2.2.
All of LCo 3.4.C and surveillance requirement 4.4.C are moved to page 109 for improved readability.
2.3 The District requests the following changes be made to page 109:
1 2.3.1.
In LCO 3.4.C.1, as a clarification, " liquid control tank" is replaced by "SLC Storage Tank," and in LCo 4.4.C " Liquid Control l
Solution" is replaced by " liquid control solution."
I 2.4.
The District requests the following changes be made to the Bases section on 5
page 110:
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2.4.1.
In the first paragraph of 3.4.A, "the reactor core" is changed to j
"the reactor pressure vessel," the system boron injection
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concentration in RPV is changed to 660 ppm, " liquid control tank" i
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is changed to "SLC storage tank," and " full power" has been changed to " RATED POWER."
For consistency with the LCos, the word "squibb" is replaced with " explosive."
i 2.4.2.
In the second paragraph of 3.4.A,
" via the Plant Nuclear Safety operational Analysis (Appendix G)" has been changed to "in Limiting l
Conditions for operation."
2.4.3.
The last three sentences of the Bases in 3.4.B have been changed to i
reflect the appropriate justification for allowable out of service time of seven days in case one SLC subsystem is inoperable.
2.4.4.
The Bases in 3.4 C are moved to page 111.
2.5.
The District requests the following changes be made to page 111.
2.5.1.
The second and third paragraphs of Bases 3.4.C are combined.
The minimum quantity of 16 percent solution required in the SLC storage tank needed to achieve 660 ppm in the RPV is changed to 3132 gallons; "66 gpm at 13 weight percent" is changed to "66 gpm of 13
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weight percent," and "SLC" is changed to "SLC system."
2.5.2.
In the first paragraph of Bases 4.4 the monthly test of the SLC pumps is changed to testing once each three months consistent with the changes to surveillance requirement 4.4.A.l.
I-the second l
paragraph, references to CNS FSAR sections are c' nged to the l
3
s, to NLS950115 Page 4 of 9 corresponding CNS USAR sections.
2.6.
The District requests that Figure 3.4.1, Sodium Pentaborate Solution Volume-Concentration Requirements, on page 112 be revised for the increased ndnimum.
concentration required to achieve 660 ppm in the RPV.
The overflow volume of'the Storage tank has also been recalculated to be 4565 gallons per Nuclear Engineering Design Calculation NEDC 93-142.
The values of the new curve from 11.5 to 16 weight percent sodium pentaborate solution are:
Concentration (Weight %)
Net Volume (Gallons) 11.5 4414 12.0 4223 13.0 3887 14.0 3599 15.0 3350 16.0 3132 2.7.
The following administrative changes are also being made to correct typographical and editorial errors:
2.7.1.
On page 1,
" Normal Operation" is changed to " Normal System Operation" and the page number for Sodium Pentaborate Solution is changed from 108 to 109, 2.7.2.
On page 6, the missing words " LIMIT" and " Switch" are being added to specifications 1.1. A and 2.1. A.1. a. (1) respectively as an editorial change;. " Thermal" is deleted in 2.1. A.1. a. (1) ; s 800 psia in 1.1.B is changed to <800 psia: All defined terms on this page are capitalized.
2.7.3.
On page.12, in the second paragraph of the Bases 1.1.C, a
typographical error in the spelling of."normally" is corrected.
Also, " Cooper" is expanded to " Cooper Nuclear Station."
"tHe" is corrected to "the."
All defined terms on this page are capitalized.
2.7.4.
On page 30, in the notes for Table 3.1.1, the following changes are being made:
a.
In Action Statement 1.B,
" POWER" has been added; b.
In Action Statement 1.C, 8 has been spelled out as "eight";
c.
Action Statement 1. D,
" Reduce turbine load and close Main Steam Isolation Valves," is being added.
This action statement was deleted in error by Proposed Change Number d
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Attachment [1-g
to NLS950115 l
Page 5 of 9 l
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100,F which was later implemented by Amendment 158.F d.
In Action Statement 7.,
trip functions a, b,
c, and d have l
been replaced by A, B,
C, and D respectively; e.
In Action Statement 7.a,
" Mode switch" has been replaced j
by " Reactor Mode Selector Switch";
t i
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In Action Statement 7.C, "at" has been inserted; g.
In Action Statement 9, "to be operable" has been inserted; I.
All defined terms on this page are capitalized.
2.7.5.
On page 77, the surveillance requirement on Table 4.2.C to test the rod block caused when bypassing the Rod Sequence Control System
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(RSCS) is being deleted. This deletion was inadvertently omitted in the Proposed Change Number 861' which was later implemented by l
Amendment 156.F All defined terms on this page are capitalized.
2.7.6.
On page 152, in the second paragraph of Bases 3.6.H and 4.6.H, the
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referenced specification is changed from "3.6.H.4" to "3.6 H.3."
i This specification was renumbered in 1985 by Amendment 92,s' but the i
specification number referenced in the Bases was not updated.
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Also, all defined terms on this page are capitalized, and in the first paragraph, " reactor operation" is changed to the defined term
" REACTOR POWER. OPERATION."
f 3.0.
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. This evaluation is performed with respect to the criteria given in 10 CFR 50.92(c).
This proposed change to the Cooper Nuclear Station (CNS) Technical F
G.
R. Horn to U.S. Nuclear Regulatory Commission, NSD920302, May 4,
- 1992, i
Proposed Change No. 100 to Techr.ical Specifications - Elindnation of Main Steam Line Radiation Monitor Scram and Isolation-Functions.
F H.
Rood to G.
R.
Horn, March 2, 1993, Cooper Nuclear Station - Amendment No. 158 to Facility Operating License No. DPR-46 (TAC No. M83786).
l' G.
R. Horn to U.S. Nuclear Regulatory Commission, NLS9100488, November 15, 1991, Proposed Change No. 86 to Technical Specifications - Rod Sequence Control System Removal / RWM Setpoint Reduction.
l F
H.
Rood to G.
R.
Horn, December 22, 1992, Cooper Nuclear Station -
Amendment No. 156 to Facility Operating License No. DPR-46 (TAC No. M82637).
i' E.
D.
Sylvester to J. M. Pilant, May 20, 1985, Amendment No. 92 to CNS Tecnnical Specifications.
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to NLS950115 Page 6 of 9
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Specifications increases the SLC system design reactor pressure vessel boron concentration.
Also, the surveillance frequency for SLC pump operability testing is decreased to once each three months.
In addition, some i-administrative changes are being requested to correct typographical and I
editorial errors.
L 3 '. l. The proposed change does not involve a significant increase in the probability or cansequences of an accident previously evaluated.
The current analysis requires the SLC system to be capable of bringing the reactor 3% Ak subcritical assuming a cold xenon free condition.
The increase in SLC storage tank boron concentration lindts will ensure this capability is maintained for future reload cores using the same 3% Ak shutdown reactivity margin without imposing restrictions in cycle exposure for current and future anticipated core configurations.
The change in the surveillance frequency for SLC pump operability testing to once each three months is in agreement with the ASME Code.
The relaxation of the testing interval for the SLC pumps decreases pump degradation, and eliminates an unnecessary burden on personnel resources without compromising plant safety.
In addition, the administrative changes only correct typographical and l
editorial errors.
Since these proposed changes do not affect precursors for any accident or transient' analyzed in Chapter 14 of the USAR, there is no increase in the probability of any accident previously evaluated. Furthermore, since these changes will ensure the ability of the SLC system to mitigate the consequences of an accident for future anticipated core designs, they do not involve a significant increase in the consequences of any accident previously evaluated.
3.2.
The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The change in the SLC storage tank boron concentration limits will ensure that a cold xenon-free reload core can be brought ~to a subcritical condition as previously analyzed. The change in the frequency of the SLC pump operability testing to once each three months is in agreement with the ASME Code.
The relaxation in the testing interval for the SLC pumps decreases pump degradation, and eliminates an unnecessary burden on personnel resources without compromising plant safety.
In addition, the administrative changes only correct typographical and editorial errors.
These proposed changes do not affect the design, function, or operation of the SLC or any other system. Also, these changes do not introduce any new modes of operation or modify existing equipment design.
Therefore, they do not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.3.
The proposed changes will not create a significant reduction in the margin of safety.
The proposed increase in the required boron concentration in the reactor pressure vessel will ensure the SLC system will be capable of bringing a cold xenon-free reload core subcritical while maintaining the 3%
Ak shutdown reactivity margin as specified in the previous operating cycle.
The change in the frequency of SLC pump operability testing to once each I
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three months is in agreement with the ASME Code.
The relaxation in the testing interval for the SLC pumps decreases pump degradation, and eliminates an unnecessary burden on personnel resources without compromising plant safety.
In fact, it increases SLC system availability.
In addition, the administrative changes only correct typographical and editorial errors.
Therefore, it is concluded that the requested changes do not create a significant reduction in the existing margin of safety as defined in the Technical Specifications.
i 4.0.
Conclusion.
l l
The District has evaluated the proposed changes described above against the criteria of 10 CFR 50.92 in accordance with the requirements of 10 CFR I
- 50. 91(a) (1). This evaluation has determined that Proposed Change Number 124 to Technical Specifications 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
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accident previously evaluated, or (3) create a significant reduction in the margin of safety.
Therefore, the District requests NRC approval of Proposed i
Change Number 124, 1
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9 Attachm:nt 1 to NLS950115 Page 8 of 9 i
APPENDIX A MARKED-UP TECHNICAL SPECIFICATIONS PAGES 1
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