ML20128E596
| ML20128E596 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/01/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20128E601 | List: |
| References | |
| GL-88-01, GL-88-1, NSD930144, NUDOCS 9302100521 | |
| Download: ML20128E596 (10) | |
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GENERAL OFFICE P.O BOX 69. COLUMBOS, NEBRASKA 68602-0499 Nebraska Public Power District
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__=___m NSD930144 February 1, 1993 I
U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 i
Gentlemen:
Subject:
Proposed Change No. 112 to Technical. Specifications Generic Letter 88-01 Incorporation Cooper Nuclear Station NRC Docket No. 50-298, DPR,
References:
1)
NRC Generic 1.etter 88-01 and Supplement 'l to Generic Letter 88-01, dated January 25,. 1988 and February 4, - 1992, respectively, "NRC Position on ICSCC in BWR hustenitic Stainless Steel-Piping" 2)
Letter from G. R. Horn (NPPD) to U.S.
NRC Document Control Desk, dated July 3, 1991, " Generic Letter 88-01 Technical Specification Changes" I
2 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 _ attachment.
-This proposed change adds the suggested wording; contained in NRC Generic Letter 88-01, and its associated t.upplement, regarding-the maximum increase in allowable.
reactor coolant leakage rate in primary containment, coolant leakage' rate test frequency, and operability requirements of the drywell; sump - flow. measuring systems. This proposed change also incorporates suggested wording regarding the inservice inspection-program for piping: identified in Generic Letter 88-01.
These proposed changes address the staff positions on. leak. detection and on
' inspection methods and personnel, as specified in Reference 1, and provides the District's response to r.hese two Stafi positions, as committed.to in Reference i
2.
Other proposed' changes? include the replacement'of various system names used to refer to the drywell air. sampling system and the sump' flow measuring' systems, along'witn other miscellaneous administrative changes.
The attached contains a description of the proposed change,- the-attendant'10.CFR 50.92 evaluation,.-and the applicable revised Technical Specification Pages in
-both final-and marked up forms. ~This proposed change has been reviewed by.the-necossary Safety Review Committees and incorporates all auendments to the CNS Facility Operating License _ through Amendment 157 issued January : 7,1993.
In rder to facilitate the orderly revision of affected plant - procedures,. the s
District requests that the amendment, < associated with. the proposed change,
-becomes effectivo 30 days after its issue date.
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U.S. Nuclear Rsguistory Commission Page 2 of 3
. February 1, 1993 By 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 information, please contact me.
Sincerely.
/
. llor%
C' n
g Nucl r Power Croup Manager CRH/dnm Attachment cc:
H. R. Borchert Department of Health State of Nebraska NRC Regional Office Region IV Arlington, TX NRC Resident Inspector Cooper Nuclear Station
.l U.S. Nuclocr Rsgulatory Commission Pags 3 of 3
. February 1, 1993 4
I STATE OF NEBRASKA)
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j PLATTE COUNTY
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G. R. Horn, being first duly sworn, deposes and says that he is an authorized
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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-stateme ts contained herein are true to the best of his knowledge and belief.
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G. R. ilorn is Subscr bed in my presence and sworn to before me this day of
, phientrum
, 1993.
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Attachment to NSD930144 Page 1 of 7 REVISED TECHNICAL SPECIFICATIONS 2
Proposed Change No. 112 Revised Pages i
135 137 149 I.
INTRODUCTION The Nebraska Public Power District (District) requests: that the NRC approve the proposed changes to the Cooper Nuclear Station (CNS) Technical Specifications described below. The proposed changes implement, in part, the guidance provided in NRC Ceneric Letter 88-01' and its - associated supplement, "NRC Position on Intergranular Stress Corrosion Cracking (IGSCC) in BWR'Austenitic Stainless Steel Piping."
This generic letter requests, in part, that licensees revise their Technical Specifications to incorporate new requirements regarding in-service inspection (ISI) of.
certain BWR piping, adopt a 2 gallon per minute-(gpm)_ unidentified leak 4
rate increase limit, increase'the frequency of checks-on Reactor Coolant-System (RCS) leakage, and specify new operability requirements for drywell sump flow-measuring systems.
By approval of - the proposed changes, described below, the two NRC staff positions on leak detection and on inspection methods and personnel will be fully addressed.
II.
DESCRIPTION OF CHANGES In accordance with Generic Letter 88-01 and its associated supplement, the District proposes the following specific changes to _ the CNS Technical Specifications to reflect the current NRC staff positions regarding leak detection and inservice inspection schedules, -methods, personnel, and sample expansion.
In addition to these changes, the -' District also.
proposes three administrative changes which involve the changing of system names in order to be consistent with system names being used in the balance of the Technical Specifications and implementing surveillance procedures, The specified changes proposed to 'the CNS Technical Specifications are detailed below:
Leak Detection Page 135, Section 3/4.6.C, Coolant Leakage a)
-Revise Limiting Condition for Operation (LCO) 3.6.C.1-to incorporate a statement which specifies that-reactor coolant leakage into the primary containment from unidentified sources shall not increase at a rate greater than 2 gpm within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. Also add a statement requiring the reactor to be in Cold Shutdown-Condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the above conditions cannot be met.
Attrchment to NSD930144 Page 2 of 7 b)
Renumber the portion of LCO - 3.6.C.2, regarding-the drywell air sampling system (renamed), to 3.6.C.3.
Revise renumbered LCO 3.6.C.3 to remove reference to the sump flow measuring systems, which is specifically addressed in the revised LCO 3.6.C.2.
c)
Revise LCO 3.6.C.2 limiting the outage time of one. sump flow measuring system to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
If leakage can be quantitatively measured by manually pumping the sump or measuring the difference in sump. level, then outage time may, instead, be limited to 30 days, d)
Add new LCO 3.6.C.4 to contain the requirements presently specified.
in LCO 3.6.C.3; to incorporate reference to the revised LCO 3.6.C.2 and LCO 3.6.C.3, discussed above.
R e p 1 a e e.
the eurrent specification statement with new statement that reads "If the requirements of specification 3.6.C.2 or 3 cannot be met, an orderly This addition of the term " requirements" provides a clarification of the term "or",
and is considered purely editorial, e)
Revise Surveillance Requirement (SR) 4.6'.C.1 to require that - RCS leakage be checked by the sump and containment atmospheric sampling systems and recorded at least one per shift, not to exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, as opposed to the current requirement of once per day.
Page 149, 3,6.C & 4.6.C, Bases f)
Add a sentence, in the middle of the first paragraph, stating that leakage limits on the order of 2 gpm increase within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period and a maximum of 5 gpm are specified in 3.6.C and are also supported in Generic Letter 88-01.
Inspection Methods and Personnel Page 137 Specification 4,6.C, Inservice Inspection a)
Renumber existing specification statement-and add. a new specification which states that the inservice inspection program'for piping -identified in Generic Letter 88-01, shall be performed in accordance with the staff positions on schedule, methods, personnel, and sample expansion, included in Generic Letter 88 01.
Administrative Chances Page 135, Section 3/4.6.C, Coolant Leakare
' n SR 4.6.C.1 a)
Replace the terms " sump" and " air sampling system" i
with the terms " sump flow measuring systems" and "drywell air sampling system", respectively. These changes make consistent the terms (system names) used in the ' subject Technica1' Specification with the system names used.in other portions of the Technical
. Specifications and applicable surveillance procedures.
b)
Replace the terms, _in LCO 3.6.C.3 (Renumbered),
" containment atmospheric radiation monitor and the containment atmospheric-sampling systems" with the term "drywell air sampling system".
Replace..the statement "one of these systems" with "this system".
l
i Attichment to NSD930144 Page 3 of 7 These changes are closely associated with the immediately-above described change and are considered as purely administrative in nature.-
Page 149, 3.6.0 6 4.6.C, and 3.6.D & 4.6.D, BASES c)
Replace the term " containment radiation monitoring unit", located in the 1st line of the 4th paragraph to Section C, with "drywell air sampling system".
This changes is closely associated with administrative chan5es a) and b),' described above, d)
Replace the statement " senses gross beta, gamma particulate and iodine" with the statement " detects gaseous, particulate, and iodine radioactivity".
This change represents a clarification; the capability of the drywell air sampling system has not been changed.
I e)
Delete the statement "as well as by ' oxygen and hydrogen analyzers",
located in Section C, 3rd line of the last paragraph.
Oxygen and hydrogen analyzers cannot detect small leaks, and this change will correct this error in this BASES section.
Editorial Changes Page 135, Section 3/4.6.0, coolant Ieakare
)
a)
Correct a typographical error in line 1 of the LCO 3.6.C.1 where the word "the" appears twice, b)
Reword the last statement "made operable sooner"'to " sooner made operable" in the last line of LCO 3.6.C.3 (Renumbered).
c)
Terms on this page which are defined in the Technical Specifications are being capitalized.
Page 137, Sections 3/4.6.E, F, and G, Jet Pumns, Recirculation Pumn Flow
-Mismatch, and Inservice Inspection, Respectively d)
Replace the term " instruments" with the term " instrument" on line 6 i
of LCO 3.6.E.1.
e)
Delete line 3.6.F,1 which states "1.
Deleted" and renumber the subsequent paragraph.
f)
Add a subparagraph number "1." to the LCO located directly below the heading to LCO 3.6.G.
g)
Terms on this page which are defined in the Technical Specifications are being capitalized.
Page 149, 3.6.C & 4.6.C, and 3.6.D & 4.6.D. BASES h)
Revise the description of the reference to:the USAR, in the-middle of the first paragraph to Section D, to read "IV 4.2.1 of the USAR".
1
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l Attachment to d
NSD930144 Page 4 of 7-p.
i)
Terms on this page which are defined in the Technical Specifications -
are being capitalized.
'As an administrative note, Page 149 is also subject to revision by Proposed j
Technical Specification Change No. 66. _ In order to facilitate the orderly -
revision of affected plant procedures, the District requests that the amendment, l
associated with_the proposed change, becomes effective 30 days after its issue j
date.
l III.
SIGNIFICANT HAZARDS DETERMINATION i
1
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10 CFR 50.91(a)(1) requires that licensee-requests for operating license i
amendments be accompanied by an evaluation of significant hazards posed by the issuance of the amendment.
This evaluation _is to be-performed with respect to the criteria given in 10 CFR 50.92(c). The following' analysis meets these requirements.
i l
This submittal is judged to consist of three changes:
i 1.
Incorporating NRC Staff position on leak detection per the _ guidance; of Generic Letter 88 01 and its supplement.
i
'2 ~.
Incorporating NRC Staff position on inservice inspection schedules,.-
i-
- methods, personnel, and sample expansion per the guidance of Generic Letter-88-01 and its supplement.
3.
Administrative changes where certain system names are replaced by system names which are more. consistent with those used -in other I
portions of - the Technical Specifications and: implementing surveillance procedures.
L_
Evaluation of-this Amendment with Resoect to 10 CFR'50.92 i
k The enclosed Technical Specifications : change :is : judged. to fiuvolve - no significant hazards based on the following:
1.
Does _ - the proposed change involve a significant - increase in the probability or consequences of an accident previously evaluated?
Evaluation The first - proposed changed addresses the - NRC position on leak:
l detection, delineated in _ Generic letter 88-01. - This change. imposes--
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a 2: gpmilimit ion the increase :of unidentified reactor coolant-leak s rate cover la =24-hour period,' ' establishes -- specific.-zoperability requirements for drywell sump flow measuring. systems, and_ increases the frequency of Reactor Coolant _ System: (RCS) : leakage. checks,- This.
proposed change provides-more = stringent T criteria ;for-the early 7
detection of unidentified leakage within primary containment. ~ This additional--restriction will enhance the ability to' detect leaksfin:
the reactor coolant pressure : boundary, thereby reducing.-.the-potential for _ a significant failure.of theH pressure boundary..
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- Additional requirements regarding the drywell sump flow measuring 1-l
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Attachment to NSD930144 Page 5 of 7-systems will provide added assurance that the sumps will always be available for the early detection of unacceptable leakage during plant operations. This change incorporates additional' restrictions into the plant Technical Specifications and does net involve the modification or addition of any plant hardware, nor does it involve a change in those plant settings that affect plant operation responses.
The District concivdes that this proposed change will not involve a
significant increase in;_the-probability or consequences of an accident previously evaluated.
The second proposed change addresses the NRC position on inservice inspection methods and personnel, delineated in Generic Letter 88 01.
This change involves the addition of a statement that commits the station to conducting.the inservice inspection program in accordance with the guidance.of Generic Letter 88 01, in regard to schedule, methods, personnel, and sample. expansion. This change incorporates additional restrictions into the plant Technical Specifications and does not result in any plant modifications or change in plant hardware.
The augmented inservice inspection program, for piping identified in Generic Letter 88 01, does not affect plant operations.
However, adoption of this augmented inservice inspection program should provide added assurance that piping, susceptible to Intergranular Stress Corrosion Cracking, will maintain integrity throughout all modes of plant operation.
Therefore, the proposed. change will not involve a significant-increase in the probability or consequences of an accident previously evaluated.
The third proposed change involves the replacement of various terms (system names) used to refer to the drywell air sampling system and the sump flow measuring systems with the terms "drywell air sampling system" and " sump flow measuring systems", respectively.
The purpose of this change is to utilize system names that are consistent with those-used in other parts of the Technical Specifications and the applicable implementing surveillance procedures.
This proposed change is administrative in nature and does not involve a change in plant operations, plant modification, or a change in plant hardware. Therefore, the proposed change will not involve a - significant _ increase ~ in the probability or consequences of an accident previously evaluated.
1 2.
Does the proposed change create the possibility for a new or different kind _of accident from any accident previously evaluated?
The first proposed change ~ addresses - the NRC position on leak detection, delineated in Generic Letter 88-01, by establishing new requirements for restricting unidentified leak rate increases, increasing the surveillance frequency for' RCS leakage, and establishing specific operability requirements for the drywell sump flow measuring systems.
Cooper Nuclear Station (CNS) is analyzed for large, unisolatable leaks in primary containment and leakage is carefully monitored to reduce the probability of this _ occurring.
This proposed change provides additional restrictions on operation with increasing leakage or inoperable monitoring equipment.
Since
Attachment to NSD930144-Page 6 of 7 this change does not result in a change to the design, operation, maintenance, or testing of the plant, a new mode of operation or failure is not' created.
Therefore, the proposed change does not -
l create the possibility for a new or different kind of accident from any accident previously evaluated.
The second proposed change addresses the NRC position on inservice inspection methods and personnel, delineated in Generic Letter 88-01.
This change adds a statement that requires piping, identified in Generic Letter 88-01, to undergo inservice inspection in accordance with NRC guidelines. This change does not result in the addition or modification of any structure, system, or component, and does not introduce or change any mode of plant operation.
Therefore, the District concludes that the proposed change does not create the possibility for a new or different-kind of accident from j
any accident previously evaluated.
The third proposed change involves the replacement of various terms (system names) used to refer to the drywell air sampling system and the sump flow measuring systems in order to utilize system names that are consistent with those used in other parts of the Technical Specifications.and the applicable implementing surveillance procedures.
This proposed change is administrative in nature and does not introduce a change in the way Technical Specifications are-interpreted or implemented.
This change does not result in the addition, deletion, or modification of any structure, system, or component, and does not introduce or change any mode of plant operation.
Therefore, the District concludes' that the proposed change does not create the possibility for a new or different kind of accident from any accident previously evaluated, i
3.
Does the proposed change create a significant reduction in the margin of safety?
i Evaluation The first proposed change addresses the NRC position on, leak 4
detection, delineated in Generic Letter 88-01. This proposed change provides ' additional restrictions to the rate of leakage increase allowed to the primary containment from unidentified' sources, along with additional testing frequency requirements.
These additional requirements enhance the ability for early detection of small leaks in' the ' reactor coolant pressure ' boundary, thereby reducing the potential'for significant failure of the pressure boundary.
This change also includes the establishment of specific operability 4
requirements - for the drywell sump flow-measuring system, This change will provide additional assurance that the sumps are available for the monitoring of-RCS leakage. There are no changes to the plant hardware and no changes to plant safety. setpoint settings resulting from this change, Therefore, this proposed change does not create a significant reduction in the margin of safety.
Attachment to NSD930144 Page 7 of 7 The second proposed change addresses the NRC position on inservice inspection methods and personnel, delineated in Generic Letter 88-01.
This proposed change involves the inclusion of piping, identificd in Generic Letter 88-01,- into.the CNS in-service inspection program per the guidance provided in the Generic Letter.
This proposed change incorporates additional restrictions into the plant Technical Specifications and there are no modifications to plant hardware or changes to the plant safety setpoint settings.
Therefore, this proposed change does not create a significant reduction in the margin of safety.
The third proposed change involves the replacement of various system names used to refer to the drywell air sampling system and the sump flow measuring systems. This proposed change is administrative'in nature.
It involves no hardware changes, plant modifications, or changes in plant operati ons. There are no changes to the plant safety setpoint settings. Therefore, this proposed change does not create a significant eduction in the margin of safety.
IV.
CONCLUSION The District has evaluated the proposed changes desaribed 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 D91 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, for the reasons-detailed above, the District requests NRC approval of this Proposed Change No. 112.
Point of Contact for further information:
David N. Madsen-(402) 563-5005 d.
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