Text

Forwards Response to 971106 RAI Re Proposed Change to Conversion to Improved Std Tss.Commitment Made by Util,Encl. W/One Oversize Drawing
	ML20197E777
Person / Time
Site:	Cooper
Issue date:	12/22/1997
From:	Graham P; NEBRASKA PUBLIC POWER DISTRICT
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	NLS970225, NUDOCS 9712300074
	Download: ML20197E777 (150)
	v • d • e

{{#Wiki_filter:, t ., j casoSfi!!="wY O Yu n aw Nebraska Public Power District " T A M h"" m___ - = NLS970225 December 22,1997 U.S. Nuclear Regulatory _ Commission e -Attention: Docu.nent Control Desk - Washington, D.C. 20555-0001 Gentlemen: Subjecti Request for Additional Information Regarding the Improved Technical Specifications r Cooper Nuclear Station, NRC Docket 50-298, DPR-46 L

Reference:

1. Letter from G..R. Horn (Nebraska Public Power District ) to US Nuclear -

M ' Regulatory Commission dated March 27,1997, " Proposed Change to CNS Techt.ical Specifications, Conversion to improved Standard Technical L Specifications" E

2. US Nuclear Regulatory Commission Letter from J. R, Hall to G. R. Horn dated November 6,1997, " Request for Additional Information Regarding the Improved Technical Specifications (TAC No. M98317)"

By Reference 1, the Nebraska Public Power District (District) submitted to the Nuclear

Regulatory Commission (NRC) Proposed Change to CNS Technical Specifications, Conversion to improved Standard Technical Specifications. In Reference 2, the NRC fonverded a request for additional information (RAI) regarding this proposed change. In response to the RAI, the District

. is providinh, as an Attachment, its response to each of the individual NRC questions. Should you have any questions concerning this mattes, please contact me. i Sincerely, P, D. Graham b [1 Vice President ofNuclear Energy / /nr: ' Attachment-Il 11'lill l'111Ill11 o nam

9712300074 971222 PDR ADOCK 05000298 P

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.-'i= '- NLS970225-- December 22,1997;_ - Page 2 of 2:. cc: Regional Administrator w/o attachment USNRC - Region IV. Senior Project Manager w/ attachment . USNRC i NRR Project Directorate IV-1 ~ Senior Resident Inspector w/o attachment USNRC , NPG Distribution w/o attachment 2 a i J.. t ~ '._w._

4 l ATTACRMENT 3 LYST OF NRC COMMITMENTS l = Correspondence No NLS970225 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments. COMMITTED DATE COMMITMENT OR OUTAGE NPPD will revise the ITS submittal 1. accordance with the N/A responses to each of the individual questions. l PROCEDURE NUMBER 0.42 l REVISION NUMBER S l PAGE 9 OF 13 l b

( Cooper Nuclear Station improved TS Review Comments ITS Section 2.0, Sefety Umits i2.0$ DOC -JFD ~ ICHANGE/ DIFFERENCE COMMENT ~l STATUS 1- . L2.- CTS 1.1.D CTS bases refers to safety limit ITS 2.1.1.3 of 18 inches above TAF to - ensure adequate decay heat The current Safety Umit (CTS 1.1.D) for the reactor vessel water removal and does not refer to level is that level shall be maintained not less than 18 inches above " normal active fuel zone." the top of the normal active fuel zone. This proposed Safety I.imit - Define differences between top (ITS 2.1.1.3) requires that level be greater than the top of the active of active fuel (TAF), top of irradiated fuel. This represents a less restrictive change because the iiradiated fuel and top of top of the irradiated fuel at CNS is less than 18 inches above the top " normal active fuel zone." How of the normal active fuel zone. The change still ensures adequate is " margin for effective action

margin for effective action in the event of a level drop.

still maintained? Explain. - NPPD Response: NPPD provides the following explanation to this question and will update DOC L2 of ITS 2.0 with supporting details: CTS 1.1.D indicates the " top of the normal active fuel zone" and the " top of active fuel (TAF)" are one and the same. Once the reactor has been operated at core k,21.0, all " active" fuel becomes irradiated to some degree. Thus, proposed ITS 2.1.1.3 speaks of TAF as the " top of active irradiated fuel." As the croposed ITS 2.1.1.3 Bases says, below 2/3 core height (TAF minus 50 inches) is where elevated cladding temperatures and clad perforation would occur from decay heat without adequate cooling capability. The proposed ITS lowest cctuation levels of the emergency coolant systems are 95.19 inches above 2/3 core height in all Modes. In the event of a loss of water level, this value provides sufficient time, in all Modes, to take effective action for maintaining or restoring the proposed ITS SL water level greater than the " top of active irradiated fuel" by using o;her water injection methoJs and sources. m. _a

3 O O O Cooper Nuclear Station improved TS Review Comments Section 3.0, LCO and SR Applicability COMMENT STATUS: CHANGE / DIFFERENCE 3O LDOC JFD' Revise DOC A.2 to 1-A.2 CTS 1.0.J reflect the correct STS LCO 3.0.1 reference to 10 ITS LCO 3.0.1 CFR. DOC A.2 states that the information contained in the first paragraph of CTS 1.0.J related to the definition of LCO is duplicative to that provided in f 0 CFR 50.36a.10 CFR 50.36a is the rule containing requirements for technical specification on effluents from nuclear power plants. It appears that this is a l typo. The correct reference is TO CFR 50.36. l \\ NPPD will revise DOC A.2 for ITS 3.0 to show 10 CFR 50.36, not 10 CTR 50.36a. NPPD Response: Reclassify this 2 A.8 STS LCO 3.0.6 change as less ITS LCO 3.0.6 restrictive and revise DOC DOC A.8 describes the addition of LCO 3.0.6 which p ovides guidance accordingly. regarding the appropriate actions to be taken when a single support system inoperability also results in the inoperability of one or more supported systems. No comp cable guidance is provided in the CTS. DOC A.8 states that the CTS and various NRC guidance documents have not provided a consistent approach to the combined support / supported inoperability, but concludes that LCO 3.0.6 was included in the STS to " clarify existing ambiguities and maintain actions within the realm of previous interpretations. Therefore, the change is classified as Administrative. Staff does not agree that this is an Administrative change. Under the CTS, any time a support l system inoperability also made a supported system inoperable, actions would have to be taken under the specifications for both system, unless c<%rwise stated. Therefore, staff believes that this is a Less Restrictive change. CNS does not " cascade" in every case under the current licensing basis, unless directed by Technical Specifications. NPPD RESPONSE: Therefore, since current plant practice is to not always " cascade," adding LCO 3.0.6 to the Technical Specifications is Administrative. DOC A.8 justifies this change.

Cooper Nuclear Station improved TS Review Comments so.c=s m ITS 3.1.3, Control Rod OperablIity 3.1.3 DOC' JFDL CHANGE / DIFFERENCE COMMENT ' STATUS' 1 LA.1 ' CTS 3.3.A.2.b and 3.3.B.1 CTS 3.3.A and bases states to ITS 3.1.3 disarm CRD electrically while iTS bases states to disarm Details of the methods for disarming control rod drives (CRDs) in hydraulically. Explain. CTS 3.3.A.2.b and 3.3.B.1 are proposed to be relocated to the Bases. These details are not necessary to ensure the associated CRDs of inoperable control rods are disarmed. ITS 3.1.3 Required Actions A.2 and C.2, which require disarming the associated CRDs of inoperable control rods, are adequate for ensuring associated CRDs r.nd inoperable control rods are disarmed. As such, thae deteils are not required to be in the ITS to provide adequate protection of the public health and safety. Changes to the Bases will be controlled by the provisions of the proposed Bases Control Program described in Chapter 5 of the Technical Specifications. NPPD Response: The Bases for proposed ITS 3.1.3 Required Action A.2 gives the direction to only hydraulically disarm a stuck control rod. NPPD will revisa DOC L1 for ITS 3.1.3 to include this change to CTS 3.3.A.2.b. The Bases for Required Action C.2 directs to electrically or hydraulically disarm nonstuck inoperable control rods. NPPD will mark up CT'i 3.3.A.2.b to show the applicability of the revised. DOC L1, as well as CTS 3.3.B.1 with new DOC L10 and associated NSHC, which will justify the allowance of disarming inoperable control rods hydraulically. 2 M.8 CTS 4.3.2.a Change is not more restrictive ITS SRs 3.1..2 and 3.1.3.3 because 30% RTP > 22% RTP. Surveillance could be yrformed The Surveillance condition described in CTS 4.3.2.a as "above 30% at or above 30%: therefore, it is rated thermal power" is proposcd to be changed to " Thermal Power noted that this is an is greater than the LPSP of the RWM," and shown in the form of a administrative change. Note to proposed SRs 3.1.3.2 and 3.1.3.3. The LPSP is set at 22%, making this a more restrictive change. This change is necessary to ensure that control rod insertion capability is verified at the earliest opportunity in the applicable conditions. NPPD Response: CTS 4.3.2.a requires the control rud notch-insertion surveillances at power levels "above 30% power." ITS SRs 3.1.3.2 and 3.1.3.3 require these tests at greater than LPSP of the RWM (22% of RTP). Since the required range of applicable power levels for the control rod exercise tests is expanded (requiring more testing) in the ITS, the change is More Restrictive. m

1 (,. p p \\s (f Cooper Nuclear Station impro)ved TS Review Comments A sis _c=mse iTS 3.1.3, Control Rod Operablitty '@S CONNENT ^ "i STATUS' 3.1.3 ! DOC' ~JFDi )* ~ ~ CHANGE /DfFFERENCE: 3 A.2 - CTS 3.3.C.3 Maximum scram insertion time Siace control rod position is only- - ITS SR 3.1.3.4 Scram time verification readable at even number increments, ITS SR 3.1.3.4 must CTS 3.3.C.3 r2 quires that the maximum scram insertion time for be adjusted to account for 90% insertion of any OPERABLE control rod not exceed 7.0 allowable maximum scram seconds. 90% rod insertion is equivalent to notch position 4.8 or - insertion times that meet the less. ITS SR 3.1.3.4 allows a maximum insertion time of 7.0 criteria of CTS 3.3.C.3. See - seconds to reach notch position 6 which is only 87.5% insertion. comment 3.1.4-1 (DOC M.2). This is a less restrictive change to the maximum control rod insertion time. NPPD Response: Since 90% insertion does not correspond to notch position 6, but corresponds to' a position between notches 4 and 5, ~ NPPD will prepare DOC L11 and NSHC for using notch position 6. L i f

O O O Cooper Nucteer Station improved TS Review Comments sw c=sme ITS 3.1.4, Control Rod Scram Times. 3.1.4-DOC ~ JFD-1 CHANGE /DfFFERENCE COMMENT STATUS 1 M.4 2 ITS SRs 3.1.4.1 and 3.1.4.4 Submit TSTF STS SRs 3.1.4.1 and 3.1.4.4 change request for CTS 4.3.C.1 this generic change. Add The wording of STS SR 3.1.4.1 could be interpreted to require testing all control phrase to rods following any fuel movement in the reactor pressure vessel (RPV)- even if proposed words in only one bundle were moved in mid-cycle. The Bases for STS SR 3.1.4.1 make SR 3.1.4.4 Bases clear the intent is to only require testing of affected control rods following fuel establish ~mg that movement in the RPV. To avoid misinterpretation of the intent, ITS SRs 3.1.4.1 individual rod and 3.1.4.4 only require testing of all rods following refueling and after shutdown testing occurs "at 2.120 days. At other times, only affected rods are required to be tested. The times other than proposed generic deviations from the STS appear consistent with the intent as after refueling." expressed in the STS Bases. NPPD Response: A generic change has been submitted to the NEl TSTF for processing. It is slightly different than what NPPD proposed in the CNS ITS submittal. Once the TSTF is finalized, NPPD will evaluate and incorporate into the CNS ITS submittal any needed changes to conform to the TSTF traveler, including any changes made along the way. 2 M.2 CTS 3.3.C.3, maximum scram insertion time Note 2 to ITS ITS 3.1.4 Table 3.1.4-1, control rod scram times Table 3.1.4-1 ITS SR 3.1.3.4, scram time verification must be adjusted to account for the Note 2 to ITS Table 3.1.4-1 refers to ITS LCO 3.1.3 to identify control rods with allowable scram times greater than 7.0 seconds to notch position 06 as inoperable. This maximum scram criteria is not consistent with CTS 3.3.C.3 which specifies the criteria as not insertion times greater than 7.0 seconds to reach 90% of insertion which is notch position 4.8 or that meet the less. Notch position 06 is only 87.5% of rod insertion travel. This requirement is criteria of CTS also identified separately in ITS 3.1.3 as incorrect for ITS SR 3.1.3.4, scram time 3.3.C.3. verification. NPPD Response: Since 90% insertion does not correspond to notch position 6, but corresponds to a position between notches 4 and 5, NPPD will prepare DOC L.11 and NSHC in ITS: 3.1.3 for using notch position 6.

O O O Cooper Nuclear Station improved TS Review Comments ITS 3.1.8, SOV Vent and Drain Valves "3,1.8-' DOC- "JFD ~ ' CHANGE / DIFFERENCE ' COMMENT STATUS 1-1 l's S 3.1.8 Actions ITS Action A is Bases 4 less restrictive CTS contain no action req.rements in the event one or more SDV vent or than STS Action A drain valves are both inoperable and open, except for a unit shutdown by the which requires a definition of operability. (CTS are based on a design with only one valve in full return to each vent or drain line.) Assuming a design change to add a valve to each operabiltiy in 7 line, the ITS propose an action requirement for one valve inoperab!e in one or days. With one more lines (Action A) to isolate the associated line(s), instead of requiring the valve inoperable in valve (s) to be restored to operable status, as required by the STS. The SDV a line, the other vent and drain valve's primary function is to isolate the SDV during a scram valve can still to contain the reactor coolant discharge. Thus, JFD 1 justifies this difference perform the by pointing out that the isolation function is satisfied if the line is isolated. In isolation function. summary: without the need ITS Required Action A.1 differs from the STS by requiring -in 7 days - to "permanerstly" isolation of the associated line,instead of requiring restoration of the SDV isolate the line vent and drain valve to operable status. This action requirement is the same wnicn requires as STS Required Action B.1, in the event both valves are inoperable Si one or periodic draining more lines (except the allowed time is 8 hours). Because of this, the Note of of the line. WNP-STS Required Action B.1 precedes the Actions table in the ITS so, hat it 2 was granted this applies to both ITS Actions A and B. JFD 1 justifies this placement of the deviation from the note by pointing ou; that in both cases, it is necessary to unisolate the line STS based on their under administrative controls to allow draining and venting of the SDV. This CLB. It is not an is done to prevent the scram on " Scram Discharge Volume Water Level-approved generic High." This difference to the STS has been approved by the NRC in the change. Revise Safety Evaluations for V7shington Nuclear Plant Unit 2 (WNP-2), the Actions and Amendment 134 and LaSalle Units 1 and 2, Amendments 89 and 94, the note to adopt respectively. the STS wording JFD 1 states the additional SDV vent and drain valves assumed by the ITS and presentation. are being installed during refueling outage RE-17, Spring 1997 such that the CNS design will match the design assumed in the STS. NPPD Response: NPPD identified this change as a beyond-scope change in the CNS ITS submittal cover letter, dated March 27,1997, in cccordance with NRC guidance for ITS submittals. As such, the change should be processed through the appropriate NRC technical branch concurrent with the processing of the CNS ITS submittal.

r Cooper Nucleer Stadon improved TS Review Comments ITS 3.2.3, Unser Heat Generadon Rate (LHGR) 5.2.31 DOC l ':JFDi i CHANGE / DIFFERENCE ~ N COMMENT < STATUS- '1-LA.1 -

1 CTS 3/4.11.8 Linear Heat Generation Hate (LHGR)

Acceptwx:e of this change is - U STS 3.2.3 Unear Heat Generation Rate (LHGR)- contingent upon NRC deterministion of CNS applicability to the General CTS 3/4.11.8 in total is not contained in the ITS and its. Electric Topical Report NEDE-24011-- requirements are moved to the Technical Requirements. . P-A (GESTAR-il), Genera! Electric Manual based upon a letter from A.C. Th.dani (NRC) to Standard Application for Reactor Fuel

J.S. Charnley (GC. " Acceptance for Referencing of dated April 7,1987, as justification for Amendment 19 to General Electric Topical Report moving CTS 3/4.11.B requirements to j

NEDE-24011-P-A (GESTAR-II), General Electric Standard the TRM. NRC reviewing. l Application for Reactor Fuel" dated April 7,1987. l. NPPD Re ponse: No response required. NPPD considers this comment to be for NRC internal tracking purposes. 1 I 1 i i .,. - -. ~

7 Ceeper Nuclear Stesien improved TS Rewiour Casunents l~ 1 ITS 3.5.1, ECCS - Operseing i ! 'CORAMIUTME STAftS 3.5;14 DOC W CHANGBDIFFBIGWCE + L1 !L14: ? CTS 4.5.A.1.e - There is ir-iate CTS 4.5.G.2 justrfication for deleting the) ' CTS Survedlance The CTS requires daily checks and a quarterly cahbration of the core Requirements. Retain the " spray header detta P instrumentetion. The ITS does not include these requirements to check and : .j c requirements. calibrate the delta P. i . CTS 4.5.G.2 requires functionally testing and celebrating the pressure instrumentation and pressure l switches which monitor the LPCI, Coro Spray, HPCI and RCIC systems switches in the ITS or provide 1 I to ensure they are full, on a quarterly bases. ITS 3.5.1 does not inceude justificatum for the omission. this requirement. l 4 !L Justification' for omitting the CTS requirements is based on duphcate. requirements in 10 CFR 50, Appendix B, Section Xil.- This section of i t the CFR deals with calibration of instruments and test equipment but-j not installed plant equipment. J j i. NPPD Response: NPPD will revise the ITS submittal to show the applicatica of new DOC LA.6, to justify relocating this information to d the USAR and to replace the L14 application. 2 CTS 4.5.A.3.f Revise the sutmattel to include the CTS requirement i CTS 4.5.A.3.f requires performing an air test on the drywell and torus. or to justify deletion of the. F headers and nozzles once every 5 years. These requirements are not requirement. - incleded in the ITS. There is no justification for deleting this CTS i requirement. NPPD Response: The CNS ITS submittal markup for CTS 4.5.A.3.f says "See CTS: 4.5.A.3.f." As this surveillance requirement deels with containment structures and components, ITS Section 3.6 provides CTS: 4.5.A.3.f with the markup and DOC. The DOC R.1 i for CTS: 4.5.A.3.f justifies the relocation of this requirement from the Technical Specifications to the USAR. t ly 1,. +n -..,n +~~ ,e.-.c n,. ... + +.- ~,.n.~.. . -.... - -. ~ ~ ~. ~., '

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s . 3; L .)' Cooper Nuclear Station improved TS Review Comments ' ITS 3.5.1. ECCS - Operating 3 5.11 " DOC? VJFDT ^ - CHANGE / DIFFERENCE CORAWENT STATUS 3. L2: CTS 4.5.A.1.b and c Revise DOC L2 with addstional

l CTS 4.5 A.3.b and c '

information such as plant-i CTS 4.5.C.1.b and c specific operating history or analyses to justify relaxing the : The Frequency of the CTS testing requirements for Containment Spray Frequency for testing the pump and valve _ operability, Low Pressure Coolant injection pump and pumps and motor operated valve operability, and High Pressure Coolant injection pump ard valve valves assooated with'CS, ] i' operability, is monthly (31 days). ITS 3.5.1 does riot include this LPCI, and HPCI. testing requirement. The CTS requirement is included in the Inservice Testing Programs on a quarterly basis (once every 92 days). This .l decre'ases the Frequency of the CTS test requirements from 31 days to 1 ,i 92 days. There is no specific documentation included or referenced to j support this test Frequency. NPPD Response: NPPD will update DOC L2 for ITS 3.5.1 and the associated NSHC, as needed, with the results of the plant test history -i rsview and evaluation of the subject pump and valve tees. 4 L18 8 CTS 3.5.A.2 ITS 3.5.1 Actions B and H are l CTS 3.5.A.5 beyond-scope issues and are l ITS 3.5.1, Required Actions B.1 and B.2 referred to the Reactor CTS 3.5.C.2 Systems Branch. CTS 3.5.E.2 ITS 3.5.1, Required Actions H.1 and H.2 ITS 3.5.1 Required Actions B.1, and B.2, allow contir ued operation for i 72 hours when one LPCI subsystem and one CS subsystem are i inoperable. - CTS 3.5.A.2, and 3.5.A.5, require entering an immediate j shutdown track for the same conoition. ITS 3.5.1, Required Actions H.1 and H.2 allow continued operation for 72 hours when one ADS i valve and one HPCI system are inoperable. CTS 3.5.C.2 and 3.5.E.2 4 require entering an immediate shutdown track for the same conr;ition. j This change extends the CTS Completion Time for both situations from i immediate to 72 hours. NPPD Response: No response required. NPPD considers this comment to be for NRC intemal tracking purposes.~ I t --n--

~ + y J Cooper Nuclear Steelon Impeeved TS Rewtow Comments yf . ITS 3.5.1, ECCS - Opereeing 4 ^ R $;C e 3,5$. DOC-QFD1<.. M, ' ~ CHAIGGWDIFFEREffCE e-. - *.

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C e 5-x21 - CTS 3.5.C.2 The reesons for spoofying a f ITS3.5.1 Required Action D.1 Completion Time of L r STS 3.5.1 Required Ac; ion C.1 immediately are not plant apecefic. tr: addition, staff ' o +< CTS 3.5.C.2 allows continued operation for a maximum of 7 days after. disagrees that the'1 hour time w"" HPCI is descovered inoperable - provideng that during such 7 days all could be confus%.,Should active components that affect operability of the ADS, the RCIC system, RCIC become inoperable both LPCI subsystems ans both core spray.suR,rstems are operable. during the 14-day Completion i i: Corresponding STS 3.5.1 Action C allows continued operation for a - Time for restoring HPCI ' 9 4 ^ maximum of 14 days for the same condition provided the RCIC system operability, the unit would is verified operable within.1 hour - by adm.nistrative means. have to be in Mode 3 within (Apparently, the STS does not consider it necessary to specify verifying the next 12 hours per ITS the operable status of the other systems - ADS,' LPCI, and core spray. Action I (STS Action G). i. because it is expected that the operators are continuously aware of Revise the submittal to adopt l j-changes in the status of these systems.) Corresponding ITS 3.5.1 the STS 1-hour Completion Action D replaces the 1 hour Completien Tirne with Immediately. Tome for verifying opersbelety il 'of the RCIC system.. .] NPPD Response: NPPD will revise the submittal to adopt the STS 1-hour Completion Time for verifying OPERABILITY of the RCIC system, '~ "by administrative means.* L i r . t i i M i) i I 4 i l

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_. m l; C :;r Nucteor Steelen improved TS Rowlew Comments j; . fTS 3.5.1, ECCS - C;M* q 1 ,m.. l - L 341 LDOC4 IJFDL /CHANGEfDIFFERENCE^ ~ N ' " COMMENT MW ! STATUS l u \\ [.. 6 L13- ' CTS 3.5.E.3 ~ Provide additional - CTS 4.6.D.5 documentation and ITS SR 3.5.1.11 and Note justification for changing the. STS SR 3.5.1.12 and Note CTS required pressure for. j performing the ADS manuel CTS 4.6.D.5 requires performmg the ADS manual roeration test once 1 operation test, from 113 psig ' per operatmg cycle with reactor pressure 2100 psig. In the event this to 920 psig, :,d the test is not performed during the required interval, CTS 3.5.E.3 requires additional time permitted to. &j performing this test within 12 hours after achieving 113 psig reactor _ perform this test after l steam pressure. ITS SR 3.5.1.11 requires the same test, with an ~ achieving 113 psig reactor equivalent Frequency of 18 months. The Note to this survedlance pressure.. l L modifies to Frequency by only requiring the test be perforr,ed within a 12-hour limit seme time, but not after achieving 113 psig, but when adequate steam pressure and flow are achieved. Adequate steam. pressure is defined in the Bases as 920 psig.1Thus, the time limit for l performmg the test is increased by the amount of time it takes to j increase pressure from 113 psig to 920 psig. In addition, the 920 psig value is bracketed in the STS Bases. This means the ITS should use a ~ i plant-specific value. DOC L13 does not explain why the 920 psig value is applicable to CNS and why increasing the time to complete the test after acheving 113 psig reactor pressure is an acceptable relaxation. j ~ ; F. ~ NPPD Response:- NPPD bases the 920-psig test pressure on the valve manufacturers' recommended test pressuras, as the Bases indicates. [ In order to justify the additional time to perform the test, NPPD provides a time line of required testing and operations that'must occur 'at. startup and the duration required for the test or operation, including the time it takes to achieve the necessary test conditions for each'of.- . t the tests. The current TS requirements 'and plant-specific implementations are the bases for this time line. The best-estimate time line. l r, hows that CTS requirements take 13 hours (minus the present ADS testing at 300 psig) after reaching 113 psig (150 psig on the time line) -l to get to'920 psig (1000 psig on the time line). The present plant-specific implementation of "within 12 hours of achieving 113 psig* to get better testing results is at 300 psig after about 8 hours. NPPD will update DOC L13 for ITS 3.5.1 to provide these results. ~ j. ' I 6 i b s 4 - { m,,, -... _ ~,,

g ?* # - s i if . EW00sstas \\; a[ "Providef a timesline; of f required testing that: mustioccur at sttrtup; and-L the duration - .{ }/' ; required forieach.tt st,1 including time. it takes: to achieve'testiconditions-forL each -

test.

-i s 'i see; attached RE 18? outage'startup and power" ascension p?an.-jThis~1s'basedYon past?- 1 e iexperienceroftrequired testing and; duration of'each test. _ { .ExplanationCofiterms.- ITaddia.:1.D.Lnumber--offa specific item used by the scheduling program.~ j c - ~.001." Original Duration",ithis isLthe expected duration of'tne task based on' } experience.-- 1 Early Start:fEarly start l time of. task. -_Early Finish:LExpected finish time if item is~ started at-the Early Start l time.- . Red" items'are: critical to,the schedule,fand can be-tied by early}fintsh of one 1 tem ] ~ i ~ ito early start of the next. ~ i sBelowtisfa. synopsis of the. attached schedule based on testing-from~ achieving 113#- L throughireachingl normal. operating pressure with bypass-valves at 50%.open. y Item SU410 ~ allows 6 hours' to. raise reactor pressure from atmospheric to 150#.113#- twill-be late in this period. ' Based on'early_ finish. time, can conclude, will.be at-113# at 05.59 Other-items,are completed: concurrently. j 6.RCIC.104; duration 1-hour. 1-hr '6.HPCI.308,JHPCI PS-68A-D' functional l' hr e6.HPCI.104,'HPCI Flow Test at 150# 1 hr 'SU440L Raise-pressure to-300# 4 hrs

6. ADS.202, ADS Manual. Valve Actuation from ASD-ADS PNL 1 hr

.6. ADS.201,' ADS Manual Valve Actuation 1 hr ..RFP-testing:to placing the 1st RFP 1.n service-is 1500 to 1859 4 hrs 1 i .SU540, Reactor pressure 800-1000# 2 hrs

SU-MS600, Mode switch to RUN

'4-hrs . SU610,- Raise ' power to 50% bypass 0200-1359 12 hrs BasedLon!the schedule, it will take about 8 hours of achieving 113# to get to the' point of testing-ADS valves, which'is. currently performed at 300#, , Randy Carlson OSR 11-24-9*/ i +i Si 9 f m rs 5 / j u. T Ji+ -.. - - -, ~

1995- . I- . L: , t Early:- Eanyo NOV .7 i DEC-' ITEM L 1;OD/ DEPT'e Start - Finish ~ ~ 29 I TIT' -y .g y-d nog 500 45 + 0 - 05NOVD8707NOV95 ' ' bP 2.1.1.2 TNCfISPEdNN8 5I RTONYAdCTONY G 01.00 00.59 { bP 2M '--~ ~ N0 - ~O~ 05NOV98 ~ 10NOV98 ~ SU CHKLISTS & LINEUP GOP 2.1.18.1 & GOP 2.1.1.2 01:00 20 59 15TGM4 1 0-07NOV9r07NOV95-MAIN TURBINE DEH FUNCTIONAL TEST 01:00 01.59 g SP 15.TG 304 15TG 301 - ~~~4 -0 ]ig58~g,jgV98~ MAIN TURBINE LUBE OIL PUMPS FUNCT TEST P 15 TG 301 1570 302 Y~~2 0 07NOV98~07NOV98~ MAIN TURBINE TRIP FUNCTIONAL 00 00 07.53 g SP 15.TG 3C2 01MM202000 0~ 0-10NOV98~ MODE SWITCH TO STARTUP & HOT STANDBY 21:00 PM05163 1-~0-QNOV98-10NOV98-INSPFr.T RFP A TURNING GEAR - PMT 21:00 21:59 kF-TGR-A l PMT -- VERIFY NO EXTERNAL LEAKAGE PM051s4 1 0 10NOV98 10NOV98~ INSPECT RFP B TURNING GEAR - PMT 21:00 21.59 g RF-TGR-A l PMT - VERIFY NO EXTERNAL LEAKAGE 8' 'O ~ jN ggggggg SU.'05 - ~ "' ~3~ o U.MS200 0 a 11NOV98~ REACTOR CRITICAL I mm + su300 1 0-- 11NOV95-11NOV98~ CONDENSER VACUUM BEING ESTABLISHED 00 00 00.59 o gg43g __g___g_33ggygg733ggygg-RAISE RX PRESS FROM ATMOSPHERIC TO 150# 00 00 05:59 SU323 o o 11NOV98~T1NOV90 CONDENSATE BOOSTER PUMP ON LINE 01:00 00 59 9 11NOV98~ APPRC X 20" var.UUM SU310 2 C 11NOV98-l02 59 01:00 g ~~"O]N V98 NV8 PLACE SJAE SYSTEM IN SERVICE 5U470 2-5 6 RCIC.iO4 ~ C ~O~ 11NOV98 11NOV98 ~ RCIC FLOW TEST AT 150 PSIG 06 00 06.59 FLOW RATE AT 150 PSIG 6 RCIC.104 ADJUSTMEN1 ON RCIC-V-37 ADJUSTMENT ON RCIC-V-37 U] ] VERIFY NO EXTERNAL LEAKS HPCI-SOV-SSV64 & SSV87 N V98 8-PM08319~~1 $1PCI SOV-SSV64, HPCI-SOV-SSV87 PM08319 1

n:

=.::..:c 're . RE 18 REV A e RX STARTUP & POWER ASCENT 4.\\ COMPETITIVIELY STRONG 2005 & BEYOND % - uma

},4 . [ Early. Early -1995 flTEM[ LOD DEPTlf Start Finish j_DEC[ OV Puo25c2 1"O]fgv00]fp5' lN SENOib8T5AK NYsNsITiikCYSd@SSV'8tiIhi0ii$I2 HPCI-SOV-SSV88 PMT PM08526 { o ]rgwrfjrps-HPCI PS-68A-D SYSTEM ISOLATION FUNCTIONAL TEST HPCr30s i b PRESS >=150 PSIG HPCI-MO-15&16 CYCLED COORD WITH 6.HPCI.303,6.HPCI 307,6.HPCI.311 Nm2 T- ' O~ gjfgc8]g}fgV98-IN SERVICE LEAK RATE TEST RCIC-HOV-HOV11 PM08002 kCIC-HOV-HOV11. RCIC-LMS-TULS1. RCIC-LMS-TUL PMT PM09002 PERFORM AS PER 7.0.8.1 sHPcn04 1-U- igOV9ryr HPCI FLOW TEST AT 150 PSIG hlOW RATE AT 150 PSIG - 6 HPCI.104 6 R CIC.311 - 2- ~O~ N V98 ~ N V98 RCIC CONTROL SYSTEM CALIBRATION TEST (SECT 8.2) SECTION 8 2 SATISIFIES ROUTINE SP 6 RCIC.102 6 RCic 311 ^ T~ -' O-- N V98-N V98 RCIC CONTROL SYS CAL (SECT 8.2)(MECH SUPT) S SECTION 8 2 SATISIFIES ROUTINE SP 6.RCIC.102 0]fgV98 ~jyfgvDS~ NCREASE REACTOR PRESSURE TO 300# SU440 4~ g ADS 702 1 0 11NOV90 11NOV98~ ADS MANUALVALVE ACTUATION FROM ASD-ADS PNL 13 00 13 69 6 ADS.202 s ADS 201-~-~~1 ~D-~ 11NOV98-11NOV98~ ADS MANUAL VALVE ACTUATION 14 00 14 59 ( I r3 Rr.101 1 o 11NOV98~1TNOV9F RFPT STOP VALVE TEST 15 00 1553 SP 15 RF.101 15 RF.'102-1 0-11NOV98~ 11NOV9r RFPT BACKUP OIL PMP&FLTR COOLER DIP A! 15 00 15 59 SP 15 RF.102 15 m 0a 1 0 11NOV98-11NOV98-RFPT THRUST BRG WEAR & FAILURE ALARM 16 00 16 59 SP 15.RF.103 - PM03679 1 MS j}N V98 j}N VD8 PERFORM VIBRATION ANALISIS RF-P B PM03679 RF-P-B CHECK COUPLING BOLTS FOR TIGHTNESS & DISCS FOR 0] NOV98 VISIBLE SIGNS OF DISTRESS PM06162 1 "- ]N V98-B RSPT EXT STM SUPPLY CHECK VLV ISLT PERFORM PER MP 7.0.81 ES-CV-11CV, & ES-CV-12CV VERIFY RFPT B IN SERVIO & ON EXTRACTION STEAM yN V98 j SU520 T-~T-N V98-PLACE FIRST REACTOR FEEDWATER PUMP IN SERVICE k GomTATT E 1 ~O-11NOV98~~11NOV9F PERFORM 500# TO 1000# DRYWELL INSPECTION 19 00 19 59 GOP 2.1.1.1 ATTACHMENT E gygg. _ 7.- 0-V98 wr mmpmamm O l I ~ E E5533 k-----*33L RE 18 REV A ~ ~~ RX STARTUP & POWER ASCENT QN COMPETITMELY STRONG 2005 & BEYOND

o 1995 -[ .j -q-Eady i Eady-3 T DEC-. 7 NOV7 ITEM i OD DEPTi Start Finish '5 ~J 5-~~22 : l29"~ l ~ ~ ~- sus 33 wA4mOV90 iW0V9F ' NANAGliklE!NYV/ALRb'6"WN 20 00 21:50 g l l PC 524 ~ ~ ~T" ~ O '~ 11NOV98 ^ 11NOV98 ~ 58# DRYWELL AIRLOCK LLRT, SP 6.PC.524 20 00 23 59 p PC-PENT X 2 PMT - PM03058,W962297(PM07227) sus 00 6 O~11NOV98 ^12NOV98-INERTING THE SUPPRESSION CHAMBER 20 00 01.59 g EHPer102 1 0 11NOVD8~11NOV98-HPCITEST FROM ASD 21:00 21:59 O PM00293 - 1~ ~O~ N V98" N V98 A RFP DISCHARGE CV - PMT F-CV-10CV PMT -VERIFY NO EXTERNAL LEAKAGE TO PERFORM PMT A RFP MUST BE IN SERVICE PM00?D4 1 0~- 1TNOV98~ 1TNOV90 B RFP DISCHARGE CV - PMT 21 00 21 59 F-CV-11CV PMT - VERIFY NO EXTERNAL LEAKAGE TO PERFORM PMT B RFP MUST BE IN SERVICE ~~~ 11NOV98711NOV98~l cliPer321 z o HPCI TURB TRIP & OPER TEST - ASD RM 21 00 22:e c !o r gV98--]N HPCI CONTROL SYSTEM READOUT - ASD RM sBPer323 a su.MS500 -O U-11NOV98~ 11NOV98-REACTOR PRESS 1000# 22 00 21:59 I bu-Ms000' ~~4 6-11NOV98-12NOV98 ~ MODE SWITCH TO RUN 22.00 01.59 6 HPCI 316 ~ 2~ ~O~ }"g'N V98~ HPCI CONTROL SYSTEM CAllBRATION TEST (SECT 8.2) N V98 l SUG10 17 ~ o 12NOV98'- 12NOVUB-INCREASE POWER TO 50% BYPASS VALVES 02.00 1359 sus 70- ' ~ ~ - - ' ~~16~ ~~0' 12NOV98 12NOV98 INERTING THE DRYWELL 02 00 17.59 g 15TG 303 2 o 12NOVD8 T2NOV98-MAIN TURBINE TRIP TESTS .14.00 15 59 l TRIP TURBINE 15TG303 THIS ALSO MEETS THE REQUIRMENTS OF SP 15.TG.302 15TG:304-~6 O~ 12NOV90 12NOV90 MAIN TURBINE TRIP (OVER SPEED TEST) 13 00 21:59 TRIP TURBINE SP 15.TG 304 SU-Ms571 T7 GNjV98-DRYWELL & SUPPRESSION CHAMBER INERTED UST DE COMPLETED WTHIN 24 HOURS FROM MODE SWTCH TO RUN R05s50 ~ ~'~ T O~ 12NOV98 ' 13NOV98 ~ TURBINC, SYNCHRONIZED 22 00 01:59 g ~ E.E-E 33 'HE. RE 18 REV A jaD ' ' ~ ~" ("d. RX STARTUP & POWER ASCENT COMPETITIVIELY STRONG 2005 & BEYOND

EarTy i Earty .1995 ~~~ 4&o. [- ~ ~ 4 NOV - -L' DEC~ ~' < ' ! ITEM LOD; DEPT ~ Start Finish U HFCl^313 I~~ TT~ 13NOV95-13NOVDB~ "gp-kdj~hih pNCYE"TES 02 00 03 59 kOGIC TEST { h15 ~ - ~8~ ~~ O ~ 13NOV98 ~ 13NOVD8~ TURBINE GENERATOR - BALANCING RUNS CJ M M 59 g CRCic309 T'~ ~0~ 13NOV98~ 13NOV98-RCIC BEGINNING OF CYCLE TEST 04 n0 05.59 g 4 g es g yse~ TURBINE GENERATOR ON LINE (20% TO 25% POWER) 5U710 ~- c-~ V-a su-us700 U 0 13NOVU8-25% FOWER 15.59 9 5U535 ~ 0-NA-N V98~ N V98-~ MANAGEMENT WALKDOWN (25% POWER) o PMOS539 ~ T ~~ 0 -~~ 13NOV98~ 13NOV98~ HOT TORQUE RWCU MANUAL VALVES 16 00 16 59 THhSE VALVES REQUIRE TORoulNG OF BODY TO BON BOLTS POST OUTAGE AT NOT & NOP PM08541 - RWCU-V-73 & PM00539 - RWCU-CV 10CV PM08540 - RWCU-V-17 NPP'TO.1 "-~3 o N V98~ V98~ OD-1 TIP TRACES AT 25% POWER ONSULT RX ENGR TO DETERMINE IF REQUIRED NFF~10 L --~13 --~0- 13NOV98' 14NOV98~ SCRAM TIMING AT 25% POWER 19 00 07:59 y NPP 10 9 q jP'102 ]Njv98~ l4N,gm-NPP 10.2 IRM POWER CAllBRATlON (25% POWER) 4 i ePERFORM SECTIONS 8.1, & e 2 OF THIS PROCEDJRE S T-0~ 14NOV98~- 14NOV96~ TURBINE GENERATOR (INCREASE POWER 25% TO 30%) 12 00 13 59 sgus7s0-- 0--- O 14NOV98-30% POWER 13 59 4 SU755 8~ ~~'U~ 14NOV98~ 14NOV98-INCREASE POWER TO 50% 14 00 21:59 SU M5700 o U~ T4NOV98~ 50% POWER 21,59 9 I! ram 301' ~t-o-14NOV98 14NOv98~ ARI LOGIC TEST WITH REACTOR IN RUN DIV 1 22 00 22 59 0 f SP 15.ARI 301 1sar101-1 O~ 14NOV9BT 14NOV98-RFPT STOP VALVE TEST 22 00 22 59 o SP 15.RF.101 15 RF.102 ~ 1 -~ O~ 14NOV98~14NOV98 ~ RFPT BACW)P OIL PMP&FLTR COOLER D/P AL 22 00 22:59 p SP 15 RF.102 15T01;01 1 0 14NOV98~14NOV95-MAIN TURB. DRAINS 22:00 22:55 0 EP [5335 ' Q E2E-RE 18 REV A RX STARTUP & POWER ASCENT d ~~ ~~~ COMPETITIVIELY STRONG 2005 & BEYOND

np Early 1995 $3TEMI: [OD dk:f%j Early-: [' " " [{}4ggyjY9.g g[~Eh' Y--m 5 Start Finish SOkkNdFi1PRM Ch'l m " "--y e-tayOV93715NOVggr 22.00

09 59 CONSULT RX ENGR TO DETERMINE IF REQUIRED RN-

~F ~ O 14NOV98 ~ 14NOV98 ARI LOGIC TEST WITH REACTOR IN RUN DIV 2 P i 23 00 23 59 o SP 15 ARI 302 15 RF~103 1 0-14NOVU8~ T W OVDB~ RFPT THRUST BRG WEAR & FAILURE ALARM 23 00 23 50 0 SP 15 RF 103 PM03c78 - 1-- Ms-15NOV98-15NOVor PERFORM VIBRATION ANALSIS RF-P-A PM03678 00 59 l00 00 RF k-A 1 CHECK COUPLING BOLTS FOR TIGHTNESS & DISCS FOR VISIDLE SIGNS OF DISTRESS SU770 2 15NOV9r 15NOV98-PLACE SECOND REACTOR FEEDWATER PUMP IN SERVICE 00 00 01:59 0 OOTA ~ ~ 6~~~O-15NOV9F 15NOV98~ OD-1 & LPRM CAL AT 50% 10 00 15 59 CONSULT RX ENGR TO DETERMINE IF REQUIRED 50780 7~ 0-~ 15NOV98-15NOVDB-INCREASE POWER 50% TO 70% to 00 22.59 e su79a - n-O~ 15NOV9r 1ENOV98~ PLACE AOG TRAIN ? IN SERVICE 23 00 1059 g 50701 ~ ' 20 ~ O~ 1GNOV98 17NOV98 INCREASE POWER 70% TO 100% (12MWe/HR) 11:00 00=59 g 1 01MM505000 o o 17NOV9r 101% POWER 0059 i I f I 9 33333'dId[ RE 18 REV A ~ Q(y ~ " " RX STARTUP & POWER ASCENT COMPETITIVIELY STRONG 2005 & BEYOND ame =, =.

.,y.. -W. 3 1 P y j

S' S'?

'~ ~ + 3 ~ 1 C .u , St.d.n.np.oeed 1S - - ITS 3.5.2, ECCS - Shutdown ~ t iO ~ 3.51 DOC fJFD? --E% CHANGElDIFFERENCE d n ' " ' W CORAENT1 C-w IE 2 STATUS . J, e1

L11

' CTS 3.5.F.5.c The' bases suggaets that NPSH, vortaming, . -I 'ITS SR 3.5.2.1 and recirculatiosVmeheup were considered ' j to determine the lower water level limit. -j 7 - CTS 3.5.F.5.c requires a Condensate Storage Tank (CST) There is no discuenion on why 80,000 - ~ 3l level of 230,000 gallons when in Mode 5 during an OPDRV. gatons of water required in the CTS are : ITS SR 3.5.2.1 requires 14 ft. (equivalent to 150,000' no longer required in the ITS. Provide

j I

gaNons) for the same conditions; There is inadequate additional h==iari describing the : . justification for the decrease in CST level. difference in analysis of the required water levels.- i r ~ NPPO. Response: NPPD is analyzing the validity of the 150,000 gallon value at CNS, t$ut will revise DOC L1 with this informetson: L

}

~

1 The basis for the 230,000 gallon CST volume in CTS 3.5.F.5.c was a value the NRC. determined adequate in CNS CTS Change 11,.

which added this requirement, for the situation in which the snppression pool is empty for required inspection and a control rod drive is.. removed for maintenance. The removal of a control rod drive is an operation with the potential for draining the reactor vessel (OPDRV).;

l The difference between that value.and the -ISO,000 gallon CST volume in CTS 3.10.B.F is that the 150,000 gallon value is for refueling 1

~ ][ l cctivities with the suppression pool empty and no OPDRV. : The acceptability of the'150,000 gallon value in the ITS can use the availability C of other sources of water that would normally be available during an outage. During OPDRVs, the NOTE to ITS SR 3.5.3.1 b.' allows only c one required subsystem to take credit for the CST volume. ITS SR 3.5.2.1 a. then requires the suppression pool svadable as a source of ? -j water for the other required low pressure ECCS injection / spray subsystem. .i h 6 3-i a L N h. n i. n ~' e. q 4 s ~I 4. <w.< , -, t nn, + n. ,,.: v, . -w .w.~,+. ,e. --a+s.~ n., n. ,,.,.L.,,+ +..J:.~ -

O O O Cooper Nuclear Statim improved TS Review Comments ITS 3.5.2, ECCS - Shutdcwn 3 5'.2 ' DOC 'JFD-CHANGE / DIFFERENCE COMMENT STATUS -2 2 STS SRs 3.5.2.1 and 3.5.2.2 Revise JFD 2 to further address the iTS SR 3.5.2.1 uniqueness of the CNS LPCI water supply design relative to other BWR/4 plants. The ITS combines the two STS SRs to verify that the water supply (ies) to the LPCI subsystem (s) and/or core spray subsystem (s) are above the minimum volume required. STS appears to assume a design in which LPCI is not capable of being aligned to draw from a condensate sturage tank (CST). Thus, STS SR 3.5.2.1 only addresses the LPCI subsystem water source - the suppression pool water level. JFD 2 indicatas that because the CST is also available to the LPCI subsystem, then the core spray water supply surveillace, STS SR 3.5.2.2, can equally apply to tht. LPCI subsystem. It appears this adaptation cf the STS to the CNS design is acceptable. But staff needs more information regarding why CNS due. differs from that l assumed in the STS. NPPD Response: The CNS plant design does allow a suction source of LPCI as being capable of taking suction from the CST, as USAR Section VI-4.4 describes. The CNS design is different in this way from other BWR/4s that have undergone the ITS upgrade process before (Hitch, Pea.:h Bottom, and Brunswick do not include this design feature). ' Thus, NPPD believes JFD 2 is adequate and needs no revision. 3 L5 OTS 4.5.G.2 Maintain the CTS requirement to ITS 3.5.2 functionally test and calibrate the low STS 3.5.2 pressure ECCS " keep filled" switches or provide justification for the omission. CTS 4.5.G.2 requires functionally testing and calibration of the low pressure ECCS " keep filled" pressure switches. See Comment 3.5.1-1 ITS 3.5.2 does not include this requirement. Justification i for omitting the requirements is based on duplicate requirements in 10 CFR 50, Appendix B, Section Xil. This ~ section of the CFR deals with calibration of instruments and test equipment but not installed plant equipment. NPPD Response: NPPD will revise the ITS submittal to show the application of new DOC LA.3, to justify relocating this inforraation to the USAR and to replace the L5 application. ~

(3 p i ~ /- V Cooper Nucteer Station improved TS Review Comments sas casm 2 ITS 3.5.3, RCIC System I .5.3 DOCI "JFD< ~ CHANGE / DIFFERENCE ' ' COMMENT 5%TUS I 4 3 1- - L3 - CTS 4.5.D.1.b Relying upon industry operating expenence CTS 4.5.D.1.c only is inadequate justification for deleting the CTS requirement for performing CTS 4.5.D.1.b and c require performing an Operability Operability tests on the RCIC pump and test on the RCIC pump and motor operated valves once motor operated valves. Provide every month. ITS 3.5.3 does not include these justification based on specific plact design requirements. Justification is based on industry plant or conditions to substantiate deleting operating experience. There is inadequate justification for these CTS surveillance requirements..- deleting this CTS requirement. NPPD Response: ' NPPD will update DOC L3 for ITS 3.5.3 and the associated NSHC, as needed, with the results of the pidnt test history :- r view and evaluation of the subject pump and valva tests. 2 L7 2 CTS 4.5.D.2 Revise the submittal to adopt the STS ' ITS 3.5.3 Required Action A.1 Completion Time of 1 hour. STS 3.5.3 Required Action A.1 See Comment 3.5.1-5. CTS 4.5.D.2 requires immediately verifying the HPCI system is Operable when the RCIC is dete,ined Inoperable. ITS 3.5.3 Action A retains this CTS requirement. However, the Completion Time of Revise DOC L7 to address changing "Immediate" dif fers from the corresponding STS time of "immediate" to one hour and to address - 1 hour. clarifying that HPCI system operability be verified by administrative means. Note: DOC L7 incorrectly describes the disposition of CTS 4.5.D.2 as being deleted; in fact it is retained as ITS 3.5.3 Required Action A.1. j t NPPD Response: NPPD will revise the submittal to adcpt the STS 1-hour Completion Time for verifying OPERABILITY of the HPCI system "by administrative means." NPPD will also revise DOC L7, its NSHC, and its application. t

m { i y. C.ep., _,mpro.ed 1S _ - lI ITS 3.5.3, RCIC System [- s STAft2 yg,3 DOC \\ W ^% CHAleGGDFFBtBICE ~ CORAMNT" T e 3; -L5

CTS 4.5.D.1.e' Changing the steem pressure stowed,for

? STS SR 3.5.3.4 '. conducting the test is referred to the ! ITS SR 3.5.3.4 Reactor Systems Branch for review. l. L ~ Bases for ITG SR 3.5.3.4, STS markup I' - page B 3.5-27 The steam pressure for performing the RCIC system cyclic flow test is changed from " approximatey 150 psig" to - "s ;165 psig," a bracketed number in the STS. The CTS q value of 150 psig should be retained, as indicated by.the brackets in STS SR 3.5.3.4. Changing the current j (. number is a beyond scope change. l Note: The proposed Bases for ITS SR 3.5.3.4 is consistent with the STS, giving a number of 150 psig. 1 Neither STS nor ITS Bases discuss the 165 psig '[ allowance - but should. NPPD Response: No response required. NPPD considers this comment to be for NRC intemal tracking purposes.. 4 L9 CTS 4.5.G.2 There is inadequate justification for : omitting the CTS requirement from tho' - q CTS 4.5.G.2 requires functionally testing and calibrating ITS. Retain the requirement to the RCIC system " keep filled" pressure switches or a functionally test and calibrate the RCIC : quarterly basis. ITS 3.5.3 does not include this pressure switches in the ITS or provide requirement. Justification for omitting the CTS justification for the omission. requirement is based on duplicate requirements in 10 CFR 50, Appendix B, Section Xil. This section of the CFR See Commen: 3.5.1-1 deals with calibration of instruments and test equipment but nom installed plant equipment. ] NPPD Response: NPPD will revise the ITS submittal to show the application of new DOC LA.2, to justify relocating this informetson to the. USAR and to replace the L9 application. a -i I .t I O 4F'm b W -'nWv N 'W T Y' G

A--

e

u

$P 'O m l. TIK m'-*M&T 'F'-W-&t "'"T aM' eW-h2 4- -c.t ar ce WA'-'-mL u me =m. em

n.. ?... [' \\ q_v_ ' "l '.;. ' f:E a v--^' .s Coe,e, Nu ee, St.d.n sp ed TS w - iTS 3.5A RCIC System g h ~ o a - g, _ s, mim 'gygygg l m g pg yms g y j_

- 5 >

Bases Beses for ITS SR 3.5.3.5, STS markup.. This is not a justifielde plant-specsfic or - 5 .2. page' B 3.5 editorial difference. Adopt the STS'- language p+;-:::f for cessoson. > -- r l The'om;ssion from the second paragraph ='-f-- 1,o the - rational for the 18-month Frequency for the RCIC - Such omissions'may occur i. _ _-7:=R the : [ automatic a<.tuation test is not besci on a plent-specific CNS ITS Bises. Unless the CNS design or..r 7 L-design difference and is not editorial. current licensing basis supports such 2 if omisssons, the STS wording should be 1 adopted. The response to this comment 1? F should address the global asaects of this~ type of Bases difference. - . l O u NPPD Response: The current plant practice at CNS is to perform this SR during startup from a refueleng outage. NPPD..will revise j j the proposed Bases for ITS SR ?.5.3.5 and the STS markup to restore the deleted and revised STS wording. There is no need to change E the associated JFD. NPPD will review the rest of the proposed CNS ITS Bases for 18-month Surveillance Requirements to determine if the - i same phrase was deleted and/or revised, and determine if CNS currently performs the associated SRs during power operation or whether..; to restore the STS wording and change the STS markup. NPPD will update each associated JFD, as needed. i i ? q i. i f '- t l-1 .t t -) L l I{;\\ 'r L 5 ) ? I t 't w

3 NRC RAI 3.5.3-5 -(V Analysis STS SR w/ CNS ITS SR-Justification CNS CTS Perforrned NRC- - IInvF for Deviation during questioned (JFD) Operation 18-mo. F Bases or Outage? Justification a 3.1.7.8. 3.1.7.8 - Yes N/A N/A 3.1.7.9 3.1.7.9 - Yes N/A N/A N/A N/A 3.1.8.3 3.1.8.3 - Yes L N/A N/A 3.3.1.1.12 3.3.1.1.11-Yes 3.3.1.1.15 3.3.1.1.13 - Yes N/A N/A N/A N/A 3.3.2.1.6 3.3.2.1.7 - Yes 3.3.2.2.4 3.3.2.2.3 - Yes N/A N/A 3.3.4.1.4 None N/A N/A 3.3.4.2.5 3.3.4.1.3 - Yes N/A N/A 3.3.5.1.6 3.3.5.1.5 - No See resolution table below. 3.3.5.2.6 3.3.5.2.5 - Yes N/A N/A 3.3.6.1.7 3.3.6.1.6 - No See resolution table below. 3.3.6.2.6 3.3.6.2.4 - No See Nsolution table below. 3.3.6.3,7 3.3.6.3.5 - Yes N/A N/A 33.7.1.5 3.3.7.1.4 - No See resolution table below. 3,3.8.1.4 3.3.8.1.3 - Yes N/A N/A 3.3.8.2.3 3.3.8.2.2 - Yes N/A N/A 3.4.5.1 None N/A N/A N/A N/A 3.5.1.10 3.5.1.9 - Yes 3.5.1.11 3.5.1.10 Yes N/A N/A 3.5.3.4~ 3.5.3.4 - Yes N/A N/A m. 3.5.3.5 3.5.3.5 - No See resolution table below. f.b v

~- NRC RAI 3.5.3-5 "(~} 'u Analysis STS SR w/ CNS ITS SR-Justification CNS CTS Performed NRC-llave? for Deviation. during questioned (JFD) Operation 18-mo, F Bases or Justification

Outage?

3.6.1.3.10 3.6.1.3.8 - No See resolution table below. 3.6.1.6.2 3.6.1.6.2 - Yes N/A N/A 3.6.1.7.3 3.6.1.7.3 No See resolution table below. N/A N/A l 3.6.1.8.3 3.6.1.8.3 - Yes 3.6.1.9.3 None N/A N/A 3.6.3.2.2 None N/A N/A N/A N/A 3.6.4.2.3 3.6.4.2.3 - Ycs 3.7.7.2 3.7.7.2 - Yes N/A N/A N/A N/A 3.7.7.3 3.7.7.3 - Yes

The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply tiuring a plant outage and the potential for an unplanned transient if:he Surveillance were performed with the reactor at power.

l' L ()

r NRC RAI 3.5.3-5 Resolution STS SR w/ CNS ITS SR. Justification for CNS CTS Performed NRC-Have? - Deviation during questioned (JFD) Opeation 18-mo F Bases or Justification * - Outage? 3.3.5.1.6 3.3.5.1.5 - No ITS Bases: Table 4.2.B -l 3.3.5.1 - 1 Logic (4)(6) .j LOGIC

2. CS Initiation, 6.1CS.304 SYSTEM NPPD Outage FUNCTIONAL will revise

3. P&V (SO) 6.1CS.304 TEST the ITS to match Cntrl; Outage the restored STS Logic (4) (6) wording.

2. RHR 6.RHR.301 Initiation, &

Outage

3. P&V Cntrl; 6.PCIS.301 Ou' age Logic (4)(6)

2. HPCI 6.HPCI.311 Initiation, Outage

\\

3. Turbine Trip, 6.HPCI.311 Outage

5. Aux Oil Pump 6.HPCI.311

& Glnd Stm Outage Exh; and Logic (4)(6)

2. ADS 6 l ADS.303 Actuation Outage

,[

l NRC RAI 3.5.3 5 O Resolution STS SR w/ CNS ITS SR. Justification for CNS CTS Performed NRC. llave? Deviation during questioned (JFD) Operation 18-mo. F liases or Justification

Outage?

3.3.6.1.7 3.3.6.1.6. No ITS Bases: Table 4.2.A 3.3.6.1 - 1 Logic Sysicms LOGIC

1. MSL iso vivs, 6.PCIS.302 SYSTEM NPPD drain vivs, &

Outage FUNCTIONAL will revise Rx Wtr smpt 6.PCIS.302 TEST the ITS to match vivs; Outage the restored STS

2. Drywell Vent 6.PCIS.301 wording.

iso vivs; Outage

3. Rx Wtr 6.PCIS.301 Cinup Sys Outage isolation, &

Rx Sys 6.RWCU.301 pump trip; Outage (

4. Drywell 6.PCIS.301

\\ Floor Draln/ Outage Equip Drain iso vlvs;

5. RIIR Sys 6.PCIS.301 iso vivs; &

Outage

6. Tip 6.PCIS.301 withdrawal; Outage Table 4.2.B Loeic (4)(6)

~ 4.11PCI 6.IIPCI.307 auto isolation, & Outage

4. RCIC 6.RCIC.307/313 auto isolation; Outage and Table 4.2.D Logiclystems Mech Vac.

6.PCIS.302 Pump Isolation Outage O

NRC RAI 3.5.3 5 O Hesolution STS SR w/ CNS ITS SR - Justification for CNS CTS Performed NRC-llave? Deviation during questioned (JFD) Operation 18-mo. F Bans or Justification

Outage?

3.3.6.2.6 3.3.6.2.4 - No ITS Dases: Table 4.2.A 3.3.6.2 - 1 Logiclystenu LOGIC 2.RxBldg. 6.PCIS.301 SYSTEh! NPPD 11 & V, Outage FUNCTIONAL will revbc and TEST the ITS to match. SGT Start; 6.PCIS.301 the restored STS and Outage wording. Table 4 2.D Logic Systems SGT Initiation, 6.PCIS.301 and Outage Rx Bldg. 6.PCIS.301 Isolation Outage ( 3.3.7.1.5 3.3.7.1.4 No ITS Bases: Table 4.2.D 3.3.7.1 - 1 Logic Sysicnu LOGIC CREF 6.PRht.318 SYSTEhi NewJFD No. Operation FUNCTIONAL 17S Bases: TEST 3.3. 7.1 - 6 3.5.3.5 3.5.3.5 - No ITS Bases: 4.5.D.I.a 6.PCIS.301/.302 3.5.3.5 - 2 Outage NPPD will revise the ITS to match the restored STS wording. ,,,....,..a

NRC RAI 3.5.3-5 Resolution i x STS SR w/ CNS ITS SR - Justification for CNS CTS Performed NRC-llave? Deviation during questioned (JFD) Operation 18 mo, F Bases or Justification

Outage?

3.6.1.3.10 3.6.1.3.8 - No ITS Bases: 4.7.D.I.c 6.PC.205 3.6.1.3 - 3 Outage NPPD will revise the ITS to match the restored STS wording. 3.6.1.7.3 3.6.1.7 3 - No ITS Bases: 4.7.A.3.b 6.1PC.203 3.6.1.71 Outage NPPD will revise O* the ITS to match the restored STS wording.

The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant outace and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

l.

O O Ceeper ph Staden improved TS Rowlew Conumente ITS 3.6.1.1. Primary Conseinement l. 3.8.1.1 . DOC-ED CHANGEfDNFERENCE ^ CORRE NT

STAft2 1'

A.2 CTS 1.0.P - Revise the CTS markup of ITS h A.13 CTS 3.7.A.2.a 3.6.1.1 to include a markup of ITS B3.6.1.1 Bases - BACKGROUND CTS 1.0.P and provide additenel L discussion and justification for I CTS 1.0.P defnes Pnmary Containment integr'ty. A rnerkup .- :-ni the details of the of CTS 1.0.P is provided 'm the CTS markup of ITS 1.0, but definition to ITS B3.6.1.1 Bases-not in the CTS markup of ITS 3.6.1.1. Justification A.2 in BACKGROUND and to ITS the CTS markup of ITS 3.6.1.1 and justification A 13 in the 3.6.1.2 and ITS 3.6.1.3. See CTS markup of ITS 1.0 both state that the definition of item Numbers 3.6.1.2-1 and a Primary Containment integnty is deleted from the ITS. This 3.6.1.3-3. is incorrect. The details of the defMion are relocated to ITS < ~ B3.6.1.1 Bases-BACKGROUND, which is a Less Restrictive (LA) change. In addition, the individual statements within the definition (CTS 1.0.P.1,1.0.P.2,1.0.P.3 and 1.0.P.4) are used as the basis for various ITS SRs and Bases statements [ in ITS 3.6.1.2 and ITS 3.6.1.3, which are Administrative and i Less Restrictive (LA) changes. See item Numbers 3.6.1.2-1 i and 3.6.1.3-3. l I NPPD Response: NPPD will revise the CNS ITS submittal to address the commen:. t l- [ i i l I I i i i E i

O O O Cooper Nuclear Station improved TS Review Comments ITS 3.6.1.1, PJmery Containment COMMUIT STATUS 3..1.1 - DOC' JFD CHANGE / DIFFERENCE 1.icensee to consider updating 2 A.4 CTS 4.7.A.1.d the Bases to include those CTS 4.7.A.2 STS SR 3.6.1.1.1 and Associated Bases portions of the 11/2/95 letter ITS SR 3.6.1.1.1 and Assocated Bases and updated TSTF-52 when OG provides revisions that are CTS 4.7.A.1.d and 4.7 A.2 specify the visual inspections and applicable to 10 CFR 50 leak rate testing requirernents for Pnmary Containment based Appendix J, Option A. on 10 CFR 50, Ayendix J. Option A as modified by approved exemptions. Even though the STS is bases on Appendix J Option A, the ITS modifies the STS to expticitly state 10 CFR 50 Appendix J Option A. to avoid confusion since Appendix J also has an Option B. This change is acceptabic. Changes to the STS with regard to Option A versus Option B are covered by a letter from Mr. Christopher

1. Grimes to Mr. David J. Modeen, NEl, dated 11/2/95 and TSTF-52. While a majority of the changes in the letter and TSTF-52 as modified by staff comments deal with Option B, some of the changes are applicable to both Option A and Option B.

f NPPD will not incorporate TSTF-52, since it was not approved at the time the CMS ITS was submitted and l NPPD Response: is still not approved. { l l l l l l l r

O J V L-Cooper Nuclear Station improved TS Review Comments ITS 3.6.1.1, Primary Containment S.6.1.1 DOC 'JFD ' CHANGFJDIFFERENCE COnamargT STATUS 3 A.4 CTS 4.7.A.2.c.2 Provide additional discussion and CTS 4.7.A.2.f.3 justification to verify that the CTS 4.7.A.2.f.4 Appendix J exemptions specified CTS 4.7.A.2.f.5 in CTS 4.7.A.2.c.2 and ITS SR 3.6.1.2.1 and Assocated Bases 4.7.A.2.f.4 are still valid ITS SR 3.6.1.3.10 and Assooated Bases exemptions at CNS and to which t licensee controlled document CTS 4.7.A.2.c.2, 4.7.A.2.f.3, 4.7.A.2.f.4 and 4.7.A.2.f.5 they have been relocated. specify exemptions to 10 CFR 50 Appendix J. The exemptions for MSIV leak rate testing (CTS 4.7.A.2.f.3) and containment air lock leak rate testing (CTS 4.7.A.2.f.5) are addressed in ITS SR 3.6.1.3.10, ITS SR 3.6.1.2.1 and their associated Bases, respectively. See item Number 3.6.1.2-3 for further concerns with regard to the air lock exemption. The exemptions for CTS 4.7.A.2.c.2 (ILRT frequency extension of up to 8 months) and CTS 4.7.A.2.f.4 (main steam line and feedwater line expansion bellows leakage testing) do not seem to be retained in the ITS or its associated Bases, except for the phrase in ITS SR 3.6.1.1.1

in accordance with 10 CFR 50 Appendix J, as modified by approved exemptions." Justification A.4 implies that all the exemptions are to be retained.

I NPPD Response: NPPD will indicate all of the exemptions to Appendix J, which are still current in the CNS CTS, in DOC LA.1 for ITS 3.6.1.1, which justifies relocating them to the CNS USAR. 4 A.5 CTS 3/4 7.A Correct this discrepancy. Justifb.ation A.5 indicates that a CTS requirement is moved to ITS 3.6.4.3, but does not identify the requirement nor the CTS location. CTS Sections 3/4.7.A.1 through 3/4.7.A.5 do ) not show requirements that are moved to ITS 3.6.4.3. NPPD Response: NPPD has determined that DOC A.5 for ITS 3.6.1.1 is not used in any of the CTS markup pages for ITS 3.6.1.1. I NPPD will delete DOC A.5 for ITS 3.6.1.1.

1 e 3.6.1.1 l DOC JFD CHANGE / DIFFERENCE COMMENT ' STATUS 5 Bases STS B3.6.1.1 Bases-APPUCABLE SAFETY ANALYSES Revise the statement 1 ITS B3.6.1.1 Bases-APPUCABLE SAFETY ANALYSES accord;c. gly. STS B3.6.1.1 Bases-APPUCABLE SAFETY ANALYSES states: " Prima.y containment satisfies Criterion 3 of the NRC Policy Statement." ITS B3.6.1.1 Bases-APPUCABLE SAFETY ANALYSES changes this by deleting *NRC Policy Statement

and replacing it with
Reference 4.* Ref. 4 is 10 CFR 50.36(c)(2)(ii). A similar change is made in all other sections of ITS B3.6. This change is incorrect: The Bases must be able to stand alone, references only provide supplemental information. Therefore, the correct change should replace "NRC Policy Statement
with *10 CFR 50.36(c)(2)(ii)*.

Reference 4 in the references may be retained if desired. NPPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from "NRC Policy Statement" to "10 CFR 50.36(c)(2)(ii)") being submitted ta the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is more correct than the statements approved by the NRC in other recently approved ITS conversions. The difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (wi;h regard to the reference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference, is consistent with other reference presentations in NUREG-1433, and has no impact on safety. Therefore, NPPD does not consider a revision necessary. 6 Bases STS B3.6.1.1 Bases - SR 3.6.1.1.1 Correct the ITS markup to 1 ITS B3.6.1.1 Bases - SR 3.6.1.1.1 include ITS SR 3.6.1.3.10 in the discussion of ITS B3.6.1.1 STS B3.6.1.1 Bases SR 3.6.1.1.1 states that failure to meet Bases - SR 3.6.1.1.1. various other STS SR 3.6.1.x.x's does not necessarily result in failure of STS SR 3.6.1.1.1. ITS B3.6.1.1 Bases-SR 3.6.1.1.1 deletes all STS SR 3.6.1.x.x's except STS/ITS SR l 3.6.1.2.1. The total deletion of the other SR 3.6.1.x.x's is incorrect. STS SR 3.6.1.2.13 MSIV leakage is retained in the h ITS as ITS SR 3.6.1.3.10. l NPPD Response: CNS CTS 4.7.A.f.1 states that the total acceptable leakage for all valves and penetrations other than MSIVs is 0.60 L CTS 4.7.A.f.3 provides separate leakage rate limits and test pressure for MSIVs. Therefore, since MSIV leakage at CNS cannot impact the ability to meet proposed ITS SR 3.6.1.1.1, NPPD will revise the statement in the ITS Bases, that failure to meet MSIV leakage does rnt necessarily result in failure of SR 3.6.1.1.1 (primary containment leakage), to reflect the CNS current licensing basis in CTS 4.7.A.f.1.

O O Cooper Nucteer Station improved TS Review Comments wu.c=ues ITS 3.6.1.2, Primary Containment Air Lock 3.6.1.2 - DOC JFD ME/ DIFFERENCE cnnsmangT STATUS 1 A.2 CTS 1.0.P.2 Revise the CTS markup of A.5 CTS 3.7.A.2.a ITS 3.6.1.2 to include a A.13 ITS B3.6.1.1 Bases - BACKGROUND markup of CTS 1.0.P.2 and ITS B3.6.1.2 Bases-LCO provide additional discussion and justification for the CTS 1.0.P defines Pnmary Containment Integnty. A markup of Adn.;..;.i..iive and Less CTS 1.0.P is provided in the CTS markup of ITS 1.0. but not in Restrictive (LA) changes of the CTS markup of ITS 3.6.1.2. Justification A.2 in the CTS relocating the airlock details of markup of ITS 3.6.1.2 and justification A.13 in the CTS markup the definition to ITS B3.6.1.1, of ITS 1.0 both state that the definition of Primary Containment ITS 3.6.1.2. and ITS B3.6.1.2. Integrity is deleted from the iTS. This is incorrect. The details of the definition with regard to CTS 1.0.P.2 are relocated to ITS l B3.6.1.1 Cases. BACKGROUND, ITS 3.6.1.2 ACTIONS, ITS SR 3.6.1.2.1 Note, and ITS B3.6.1.2 Bases which are Administrative and Less Restrictive (LA) changes. See item Number 3.6.1.2-7. NPPD Response: NPPD will revise the CNS ITS submittal to address the comment. 2' A.4 CTS 4.7.A.2.f.5 Licensee to consider updating STS SR 3.6.1.2.1 and Associated Bases ITS SR 3.6.1.2.1 Notes and ITS SR 3.6.1.2.1 and Associated Bases Assoosted Bases to inchsde those portions of the i1/2/95 See item Number 3.6.1.1-2. letter and updated TSTF-52 when OG provides revision that are applicable to 10 CFR I 50 Appendix J. Option A. I NPPD P@.e.: NPPD will not incorporate TSTF-52, since it was not approved at the time the CNS ITS was sutmutted and is still not yet approved. h

s - s o Cooper Nucteer Station improved TS Review Comments sm.c=am ITS 3.6.1.2, P.~.-._, Containment Air Lock 3.6.1.2 DOC JFD-CHANGE / DIFFERENCE COMMENT STATUS 3 A.4 CTS 4.7.A.2.f.5 Provide additional discussion ITS SR 3.6.1.2.1 and Associated Bases and justification for this relocation of details. CTS 4.7.A.2.f.5 specifies the leak rate testing for the Prwnary Containment Air Lock, which contains an exemption from 10 CFR 50 Appendix J Option A. While the specifics of the exemption are included in ITS SR 3.6.1.2.1, the details of the performance of the test are relocated to the ITS B3.6.1.2 Bases-SR 3.6.1.2.1. Justification A.4 does not address this relocation of details to the Bases. NPPD Response: NPPD provided the justification for moving the details of performing the test to the Bases of ITS 3.6.1.2 in DOC LA.1 for ITS 3.6.1.2. NPPD will revise the CTS markup for CTS 4.7.A.2.f.5 to reflect the LA.1 annotation instead of the A.4 annotation. [ 4 A.4 3 CTS 4.7.A.2.f.5 Provide additional discussion ITS SR 3.6.1.2.1 and justification to show that the O.23 scfh leakage rate is ITS SR 3.6.1.2.1.b specifies an overall air lock leakage rate of based on current licensing s O.23 scfh when tested at 2 3 psig. CTS 4.7.A.2.f.5 does not basis. specify a leakage rate for the 3 psig air lock leakage test. However, CTS 4.7.A.2.i.5 does state that for test pressures less I than 58 psig, the leakage is adjusted to the equivalent value at 58 psig. No discussion or justification is provided to show from where the 0.23 scfh leakage rate came. 6 NPPD Response: NPPD will provide a More Restrictive DOC for the change. r h

,m d Cooper Nucieer Station improved TS Review Comments wa_aues ITS 3.6.1.2, Primary Containment Air Lock 3.6.1.2 DOC JFD' ' CHANGE / DIFFERENCE COMMDIT STATUS' S M.1 STS SR 3.6.1.2.2 Ucensee to update submettal ITS SR 3.6.1.2.2 and Associated Bases to be in accordance with TSTF-17 or provide additionel STS SR 3.6.1.2.2 verifies that only one door in the air lock can justification for the deviations be opened at a time on a frequency of 184 days. TSTF-17 based on current licensing modifies STS SR 3.6.1.2.2 and associated Bases by deleting the basis, system design or Note and changing the frequency to 24 months. ITS SR operational constraints. 3.6.1.2.2 and its associated Bases implement TSTF-17: howefer, the SR frequency and Bases changes are not in accordance with TSTF-17. ? NPPD Response: NPPD will revise the CNS ITS submittal to reflect the NRC approved version of TSTF-17. 6 CTS 3.7.A.2.a Correct this discrepancy. ITS 3.6.1.2 Action A Justification L2 states the following:" Proposed ITS 3.6.1.2 ACTION A is proposed to be added to CTS 3.7.1.2...". There is no CTS 3.7.1.2 in the CTS markup. NPPD Response: NPPD will revise DOC L2 for ITS 3.6.1.2, from

CTS 3.7.1.2" to
CTS 3.7.A.2.*

I s k r

pO N Q Cooper Nuclear Station improved TS Review Comments mm cwors ITS 3.6.1.2, Primary Containment Air Lock 3.6.1.2 DOC JFD CHANGE /DfFFERENCE - COMMENT STATUS 7 L2 CTS 1.0.P.2 Reclassify this change as More CTS 3.7.A.2.a Restrictive and provide ITS 3.6.1.2 ACTION A additional discussion and justification as appropriate. CTS 3.7.A.2 requires containment integrity. The CTS definition of containment integrity (CATS 1.0.P.2) requires at least one OPERABLE air lock door. ITS 3.6.1.2 ACTION A is added to provide Required Actions when one air lock door is inoperable. The justification for this change (L2) is classified as Less Restrictive. However, this change adds Required A':tions where none were required by the CTS and is, therefore,.f. ore Restrictive. NPPD Response: While the CTS definition of Primary Containment Integrity only requires one door in the airlock to be closed and sealed. CTS 4.7.A.2.f.5 requires testing of the airlock, not just one door. CTS 1.OY states that performance of a Surveillance Requirement within the specified time interval shall constitute compliance with the operability requirements of an LCO. Therefore, some action is required if one of the airlock doors is found to be inoperable. Since no action is currently specified for this condition, NPPD considers the addition of ITS 3.6.1.2 ACTION A to be a Less Restrictive change, not More Restrictive. 8 Bases ITS B3.6.1.2 Bases - APPLICABLE SAFETY ANALYSES See item Number 3.6.1.1-5 1 ITS B3.6.1.2 Bases - REFERENCES See item Number 3.6.1.1-5 NPPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from "NRC Policy Statement" to ~10 CFR 50.36(c)(2)(ii)*) being submitted ta the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is more correct than the statements approved by the NRC in other recently approved ITS convers:ons. The difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the reference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference, is consistent with other reference presentations in NUREG-1433, and has no impact on safety. Therefore, NPPD does not consider a revision necessary.

Cooper Nucteer Stadon improved TS Review Comments wa.amme ITS 3.6.1.3, Primary Conteinment teolation Valves (PCIVs) 3.6.1.3-DOC ' ' 'JFD - CHANGE / DIFFERENCE COhMENT - STATUS 1 A.4 3-CTS 3.7.A.2.b Revise the ITS markup of Bases STS SR 3.6.1.3.2 Note 2 ITS SR 3.6.1.3.1 Note M 3 ITS SR 3.6.1.3.1 and Associated Bases - reflect CTS 3.7.A.2.b Bases requirements. Provide 6-CTS 3.7.A.2.b allows the Drywell and Suppresseon Chamber Purge additional descussion and and Vent Systems to be in operation with the 24 inch supply and justification as necessary exhaust valves open provided that if venting and purging is through for this change. See item the Standby Gas Treatment (SGT) System, both SGT trains shall be Numbers 3.6.1.3-2 and OPERABLE and only one SGT train shall be in operation. This 3.6.4.3-8. condition is not s.pplicable provided the 2 inch bypass lines are used. Note 2 to STS SR 3.6.1.3.2 is modified in the ITS to address this requirement. The Note in ITS SR 3.6.1.3.1 as proposed does not meet the intent of the CTS requirements. It would allow venting and purging to continue with one SGT subsystem inoperable. This is unacceptable. In addition, the justification (3) used to add the Note justifies deleting purge valve leakage limit SRs not the adding of this Note. See item Numbers 3.6.1.3.2 and 3.6.4.3-8. t NPPD Response: NPPD will revise the Note to ITS SR 3.6.1.3.1 to reflect that two SGT subsystems must also be OPERABLE when the pur;;e and vent valves are open. In addition, NPPD will provide a new JFD for this change. The JFD will discuss the change as being made ta reflect the current licensing basis in CTS 3.7.A.2.b. I i

O O ( Cooper Nuclear Station Improved TS Review Comments me_c-sms ITS 3.6.1.3, Primary Containment Isoission Vahies (PCivsl 3.6.1.3 -DOC "JFD-CHfJ0GE/DIFFEROWCE COasassasT ' STATUS ~ i 2 A.4 3 CTS 3.7.A.2.b Revise the ITS 3.6.1.3 Bases ITS 3.6.1.3 ACTIONS ACTIONS as necessary 3 ITS SR 3.6.1.3.1 and provide the Bases ITS 3.6.4.3 ACTIONS appropriate descussions 6 and justifications. See Because of the plant specific requirements associated with item Number 3.6.4.3-8. CTS 3.7.A.2.b, a Note has been added to ITS SR 3.6.1.3.1 (See item Number 3.6.1.3-1.) and the staff proposes ACTIONS be included in ITS 3.6.4.3 with regard these requirements (See item Number 3.6.4.3-8). Consideration should also be given to adding appropriate Conditions, Required Actions and Completion Times to ITS 3.6.13 to supplement the proposed staff requirements of ITS 3.6.4.3 ACTIONS. i NPPD Response: NPPD believes that, with the revision to the Note to ITS SR 3.6.1.3.1 discussed in the response above, it is not necessary to provide the suggested actions. Not including the suggested actions is equivalent to the approach used in the NUREG-1433 Note 2 to SR 3.6.1.3.2 (i.e. if the affected purge valves are open for reasons other than described in Note 2, SR 3.6.1.3.2 would not be met and purging must be immediately suspended, or compliance with the provisions of Note 2 must be immediately obtained, or I.CO 3.0.3 t would have to be entered.) 3 A.13 CTS 1.0.P.1 Revise the CTS markup of E M.7 CTS 1.0.P.3 ITS 3.6.1.3 to include a CTS 1.0.P.4 markup of CTS 1.0.P.1, 3 ITS 3.6.1.3 - SRs and Associated Bases 1.0.P.3, and 1.0.P.4 and provide additional [ CTS 1.0.P defines Primary Containment Integrity. A markup of discusseon and i CTS 1.0.P is provided in the CTS markup of ITS 1.0, but not in the ju.i;';ceion for the f CTS markup of ITS 3.6.1.3. Justification A.13 in the CTS markup of Administrative /Less i ITS 1.0 statec that the definition of Primary Contamment Integrity is Restrictive changes. deleted from the ITS. This is incorrect. The details of the definition with regards to CTS 1.0.P.1,1.0.P.3 and 1.0.P.4 are relocated to ITS B3.6.1.3 Bases-BACKGROUND and to various ITS 3.6.1.3 SRs. which are Less Restrictive (LA)/ Administration changes. i t MPPD Response: NPPD will revise the CNS ITS submittal to address the comment. _.,m_

O O O Cooper Nucteer Steden improved TS Review Comments = 9 cmamos ITS 3.6.1.3, Primary Containment leelseien Vafwes (PCIVs) - 3.6.1.3 DOC IJFDL ~ CHANGEfDIFFERENCE COMMENT STATUS' 4 . M.2 1 CTS 4.7.D.1.a Provide additional Bases ITS SR 3.6.1.3.5 and Assooated Bases discusse and 2 justification for the IST CTS 4.7.D.1.a requeres verifying the closure time (isolation time) of isolation time frequency the PCIVs on a frequency of one.e per operating cycle (18 months). change for those PCIVs ITS SR 3.6.1.3.5 will perform this requirement in ins.vid.i.c.e with that are not tested on a the in service Testing Program (IST). This change in frequency is quarterly frequency. based on the tact that the IST program requires testing of some PCIVs every quarter. Thus the change is considered More i Restrictive. While the staff does not disput' ne PCIVs may have to be tested for isolation times on a r u m .m no i mention is made in the justification (M.2) as to the isolation time test frequency for the balance of the PCIVs. Will the IST isolation time test frequencies for the balance of the PCIVs be less than once per operating cycle (18 months) (More Restrictive change),18 months (Administrative change), or greater than 18 months (Less Restrictive)? j NPPD Response: NPPD will determine the various isolation time (stroke time) testing frequencies for the other PCIVs (i.e., every Cold Shutdown that is scheduled to exceed a certain time period) and add these details to DOC M.2 for ITS 3.6.1.3. i t i 4 -<p--+r__ 'e g.--- 4g w y y- .ie- - + rr. ,-,y+ ,y -9. y-+--+ , pw ,,.,g-yyw ,-r-,, -,yn,..,,gyw,

,.s ( Cooper Nucleer Station improved TS Review Comments ms c== ITS 3.6.1.3, Primary Containment isolation Vahres (PCIVs) STATUS ! 2 3.6.1.3 DOC JFD' CHANGE / DIFFERENCE COMMENT 4 M.2 1 CTS 4.7.D.1.a Provide additional Bases ITS SR 3.6.1.3.5 and Associated Bases discussion and 2 justification for the IST f CTS 4.7.D.1.a requires verifying the closure time (isolation time) of isolation time frequency the PCIVs on a frequency of once per operating cycle (18 months). change for those PCIVs ITS SR 3.6.1.3.5 will perform this requirement in accordance with that are not tested on a the in service Testing Program (IST). This change in frequency ir quarterly frequency. based on the fact that the IST program requires testin0 of some PCIVs every quarter. Thus the change is considered More Restrictive. While the staff does not dispute that some PCIVs may have to be tested for isolation times on a quarterly frequency, no mention is made in the justification (M.2) as to the isolation time test frequency for the balance of the PCIVs. Will the IST isolation tirrie test frequencies for the balance of the PCIVs be less than once per operating cycle (id months) iMore Restrictive change),18 months (Administrative chenge), or greater than 18 months (Le.ss Restrictive)7 NPPD Response: NPPD will determine the various isolation time (stroke time) testing frequencies for the other PCiVs (i.e., every Cold Shutdown that is scheduled to exceed a certain time period) and add these details to DOC M.2 for ITS 3.6.1.3. l l t

n ~ Cooper Wh Station improved TS Review Comments miemm ITS 3.6.1.3, Primary Containment isolosion Valves (PCIVsl 3.6.1.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ( '5 M.6 6 CTS 3.7.D Delete this genenc STS 3.6.1.3 ACTION I change. ITS 3.6.1.3 ACTION F ITS 3.6.1.3 ACTION F is proposed to be added to CTS 3.7.D in the event any RA and associated Completion Time cannot be met in

l MODES 4 and 5. STS 3.6.1.3 Condition I defines the acisayra OPDRVs in Condition I. ITS 3.6.1.3 ACTION F removes the phrase

" Operation with a potential for draining the reactor vessai (OPDRVs) from Condition F and places it in P.A F.1 in place of *OPDRVs.* The justification (M.6) states that the only OPDRVs that need to be suspended are those associated with the RHR Shutdown Cooling System. The justification does not provide adequate justification as to why ITS 3.6.1.3 ACTION F should not apply to the oths OPDRVs implied by the justification. Since the ras are connected by an "or* there is no guaranty that RA F.1 will be used for when the RHR valves are inoperable rather than RA F.2. While the staff cont,iders the addition of ITS 3.6.1.3 ACTION F as acceptable, the staff has determined that the modifications made are a generic change which is beyond the scope of review for this conversion. NPPD Response: NPPD revised Condition I to delete "or during operations with the potential for draining the reactor vessel (OPDRVS)." Co dition I describes the applicability for required PCIV(s) in MODES or conditions other than MODES 1,2, and 3. ITS 3.3.6.1 and i ITS 3.6.1.3 requise all PCIVS to be OPERABLE in MODES 1,2, and 3, and the RHR shutdown cooling isolation valves to be OPERABLE i during MODES 4 and 5. Therefore, NPPD made the change to Condition I to be consistent with the CNS ITS since the CNS ITS does not require PCIVs to be OPERABLE during OPDRVs. NUREG-1433 brackets Condition I. The NRC has not treated changes to bracketed information in the NUREGs as beyond-scope issues during past ITS conversion reviews. Therefore, NPPD does not view this change as generic. In addition DOC M.6 for ITS 3.6.1.3 does not state that the only OPDRVs that need to be suspended are those assooeted with the RHR Shutdown Cooling System. [ i l i .~

\\'s d s Cooper Mar 4aar Station *..w..d TS Review Comments ses.casm ITS 3.6.1.3, Primary Containment isolecion Vatwas (PCIVs) 4 ' 3.6.1.3 DOC.- TJFD-CHANGE /DIFFERDfCE COsmasati STATUS 6 L9 .4 CTS 1.0.J. Delete this generic Bases CTS 3.7.A.2.a change. 6 . CTS 4.7.A.2.f.3 STS 3.6.1.3 ACTION D and Associated Bases ITS 3.6.1.3 ACTION D and Assooated Bases CTS 4.7.A.2.f.3 specifies the MSIV leakage limits while CTS 1.0.J and 3.7.A.2.a specify the remedial actions to take upon discovery of leakage rates exceeding specified limits. CTS 4.7.A.2.f.3 provide additional operability requirements. and remedial actions in which to complete the repairs and retests associated with CTS 4.7.2.f.3. ITS 3.6.1.3 Condition D changes STS 3.6.1.3 Condition D from " Secondary containment bypass.dakage rste not within limit" to "One or more penetration flow paths with one or more MSIVs not within leakage limits." Based on STS B.3.6.1.3 Bases RA D.1 discussion. STS 3.6.1.3 Condition D includes both secondary cor.tainment and MSIV leakage. Therefore, the proposed change to Condition D is acceptable. However, the change of the Completion Time associated with RA D.1 from 4 hours to an ITS time of 8 hours is not adequately justified. The justification used is consistency with the Completion Time of RA A.1. The Completion Time assocated with STS 3.6.1.3 RA D.1 takes into account the safety significance of conteir. ment leakage versus valve inoperability. Thus the STS Completion Time for leakage is less than the Completion Time for an inoperable MSIV. l In addition, the staff finds this change to be generic and beyond the scope of review for a conversion. l 1 NPPD Response: A genuic change has been submitted to the NEl TSTF for processing. i I i

Coopar Nuclear Station improved TS Review Comments wis.o w ee ITS 3.6.1.3, T.'.c, Containment isolecion Vahres IPCivs) 3.6.1.3 -DOC JFD-CHANGE / DIFFERENCE COMMENT STF ( 7 7 STS SR 3.6.1.3.2 and Assooated Bases Revise the sutettal 'l Bases STS SR 3.6.1.3.15 end Assocated Bases justif cation to justify the 3 ITS SR 3.6.1.3.1 and Associated Bases change based on plant ITS SR 3.6.1.3.11 and Assocated Bases special nomenclature. STS SR 3.6.1.3.2. SR 3.6.1.3.15 and their assooated Bases refer to purge valves. In the same situation ITS SR 3.6.1.3.1, SR 3.6.1.3.11 and their assocated Bases refer to purge and vent valves. The justification (7) is based on bemg consistent with similar guidance in other r,pecifications and not on plant specific considerations. This justification is not applicable to this plant specific case. NPPD Response: NPPD will revise JFD 7 to also state that changes are also made to reflect plant specific nomenclature. 8 Bases ITS B3.6.1.3 Bases - RA C.1 and C.2 Delete this change. 1 ITS B3.6.1.3 Bases - RA C.1 and C.2 adds a sentence to the second paragraph. The additional sentence is justified (Bases 1) on editorial clarification. The sentence does not clarify.he paragraph and only repeats what is said in the first sentence of the paragraph. NFPD Response: NPPD will delete the added sentence in the second paragraph of the proposed Bases for ITS 3.6.1.3 Required Actions C.1 and C.2.

/3 ('~) h V Cooper Nucteer Station improved TS Review Comments w e.c=ue. ITS 3.6.1.3, Primary Containment isoledon Valves (PCIVs) 3.6.1.3 DOC

JFU CHANGE / DIFFERENCE COtanEENT STATUS l.

9 Bases STS B3.6.1.3 Bases-RA C.1 and C.2 Delete these changes. ~ 1 STS B3.6.1.3 Bases-SR 3.6.1.3.3 STS B3.6.1.3 Bases-SR 3.6.1.3.4 ITS B3.6.1.3 Bases-RA C.1 and C.2 - ITS B3.6.1.3 Bases-SR 3.6.1.3.2 ITS B3.6.1.3 Bases-SR 3.6.1.3.3 ITS B3.6.1.3 Bases-RA C.1 and C.2 changes the STS B3.6.1.3 Dases-RA C.1 and C.2 words in the third paragraph from "v tves and blind flanges" to

isolation devices.* l.ikewise ITS B3.6.1.3 Bases for SR 3.6.1.3.2 and SR 3.6.1.3.3 changes the STS word *PCIV" to
isolation device"in numerous places. In the first case the word change to
isolation devices" was proposed in TSTF 196 which has been rejected by the staff. In the other case, the paragraphs and sentences that refer to *PCIVs* are discussing valves and not blind flaages. Therefore the correct terminology to use is the STS wording
PCIVs." Isolation devices refer to more than just PCIVs and blind flanges.

NPPD Response: NPPD did not make these changes to be consistent with TSTF-196. Rather NPPD made the change to be consistent with similar statements in other g ortions of the Bases of NUREG-1433 STS 3.6.1.3. In the first case, the term

isolation devices
refers to the valves and blind flanges specified in ITS 3.6.1.3 Required Action C.1 similar to the manner in which the assooated Bases addresses the valves and blind flan 9es in ITS 3.6.1.3 Required Action A.1. Since the Bases can not change the requi-ements of the Technical Sprifications and the Technical Specifications still require the use of valves and blind flanges, the term *isclation devices" refers to those devices specified in the Technical Specifications. In the second case, if the Bases only refers to PCIVs 0.e., valves), this would mean that the associated S srvei!!ance Hequiren.ents are only applicable to valves. This is incorrect, since the subject Technical Specification l

Surveillance Requirements are applicabic to both valves and blind flanges, and the Bases cannot change Technical Specification requirements. Therefore, the term

isola @n device" refers to both valves and blind flanges.

v I I f ve v v w c-w w.e r*~ w-e u-e-= +

Cooper Nucteer Station improved TS Review CAwnents m s. css m ITS 3.6.1.3, Primary Containment leMm Vtt*w (PCWs) , =w

== l g _3.6.1.3 DOC ~JFD CHANGE / DIFFERENCE W.h-- COeWENT ~ STATUS-a .n 1 ~0 Bases ITS B3.6.1.3 Bases - APPUC4LE SAFETY ANALYSES

See item Number 3.6.1.1-1 3.

ITS B3.6.1.3 Bases -REFERENCES S See item Number 3.6.1.1-5 NPPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Boses before the Generic Editorial Change (which proposed the change from *NRC Policy Statement

to *10 CFR 50.36(c)(2)(ii)*) being submitted tithe N9C in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is more correct than the statements approved by the NRC in other recently approved ITS conversions.

The difference between the wording of the Generic Editorial Change and the wordnp of the CNS ITS Bases (with regard to the reference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference,is consistent with other reference presentations in NU9EG-1433, end has na impact on safety. Therefore, NPPD does not consicer a revision twecessary. 11 Bases' ITS SR 3.6.1.3.11 Revise ITS B3.6.1.3 3 STS B3.6.1.3 Bases-LCO Bases-LCO as oroposed to ITS B3.6.1.3 Bases-LCO reflect ITS SR 3.6.1.3.11 and provide the ITS B3.6.1.3 Bases-LCO deletes the fol! wing STS B3.6.1.3 Bases-appropriate discussion LCO sentence from the second paragraph: "The (18] inch purge and justification. valves must be maintained sealed closed [or blockedl to prevent full opening." Justification used (Bases 3) is a general addition / deletion justification, which is not applicable in this case. Because of ITS SR 3.6.1.3.11 the deleted statement is partially carrect-that portion dealing with valve blockage. Therefore, the sentence should be { retained in the following form: "The inch 24 inch purge and vent valve is blocked to prevent full opening." NPPD Response: NPPD will revise the affected Bases section to state, "The inboard 24 inch purge and vent valves are blocked to prevent full opening," and provide the appropriate discussion and justification. t 4 m -*..--c w ..--,v er -v*i +=w +-m - =~= * * - - - - - - - - - - - - - - - - - - - -

n O (" b) \\ Cooper Nuclear Station improved TS Review Comments w:tomws ITS 3.6.1.3, Primary Containment Isoletion Valves (PCIVs) 3.6.1.3 DOC JFO - CHANGE / DIFFERENCE COMMENT STATUS 12 Bases STS B3.6.1.3 Bases-SR 3.6.1.3.2 Either delete this change 6 ITS B3.6.1.3 Bases-SR 3.6.1.3.1 or provide additional discussion and The second and third sentences ir. STS B3.6.1.3 Bases-SR 3.6.1.3.2 justification for this state the following: "If a purge valve is open in violation of this SR, deletion based on current the valve is considered inoperable. If the inoperable valve is not licensang basis, system otherwise known to have excessive leakage when c!osed, it is not design or operational considerrd to have leakage outside of limits.* ITS B3.6.1.3 Bases-constraints. SR 3.6.1.3.1 deletes these sentences based on the justification (Bases 61 of changes made to the specificaticn. This justification is inadequate, since no changes were made to ITS SR 3.6.1.3.1 which would justify these deletions. NPPD Response: NPPD will add back the first of the two sentences discussed in this comment into the CNS ITS Bases. NPPD wiil provide an additional JFD for deleting the second of the two sentences. The JFD will say that the CNS CTS do not include individual purge and vent valve leakage limits. 13 Bases STS B3.6.1.3 Bases-SR 3.6.1.3.2 Delete this change or 6 ITS B3.6.1.3 Bases.SR 3.6.1.3.1 ' provide additional disum and The third sentence from the end of STS B3.6.1.3 Bases - justification for this SR 3.6.1.3.2 states the fo!!owing: "The [181 inch purge valves are deletion based on current capable of closing in the environment following a LOCA.* ITS licensing basis, system l B3.6.1.3 Bases - SR 3.6.1.3.1 deletes this sentence based on the design, or operational justification (Bases 6) of changes made to the specification. No constraints. changes were made to ITS SR 3.6.1.3.1 which would require this change. In addition, changes made to the ITS B3.6.1.3 Bases-i BACKGROUNO and ITS SR 3.6.1.3.11 imply that the purge valves automatically close during or following a LOCA. NPPD Response: While the purge valves are fully capable of closing in the environment followmg a LOCA, NPPD will provio'e additional just;fication and modify the affected portions of the Bases Background section and the Bases for SR 3.6.1.3.11 according to the current ( CNS licensing bases. i = -. -

/G ) T U J x.) Cooper Nuclear Station improved TS Review Comments me.c== ITS 3.6.1.3, Primary Containment isoletion Velves (PCIVs) l 3.6.1.3 DOC l 2 JFD' CHANGE / DIFFERENCE'- COtmSENT STATUS 14 Bases STS SR 3.6.1.3.13 and Associated Bases Add Note to ITS SR 6 ITS SR 3.6.1.3.10 and Associated Bases 3.6.1.3.13 and retain 3ases description of The Bases for STS SR 3.6.1.3.13 refers to a Note 1 while STS SR Note. Provide additional 3.6.1.3.13 does not show a Note. Therefore, the Bases discussion justification and on the Note was deleted from the ITS SR 3.6.1.3.10. This is an discussion to support this enor. The Note should be added to ITS SR 3.6.1.3.10 and the change. de-ussion retained in the Bases. This Note deals with leakage limit appliobility and is associated with ITS 3.6.1.3 ACTIONS Note 4. Also, BWR 16 C.5 conected this enor. This error has been conected by TSB-10 NPPD Response: ITS 3.6.1.3.10 verifies that the leakage rate of each main steam isolation valve is within the required limit. The main steam isolation valves are only required to be OPERABLE, in accordance with the Applicability of ITS 3.6.1.3. in MODES 1,2, and 3. The additional Applicability in ITS 3.6.1.3, "When associated instrumentation is required to be OPERABLE per ITS 3.3.6.1, 'Pnmary Containment isolation System Instrumentation.** does not require main steam isolation valves to be OPERABLE in MODES or specified cWitions o*her than MODES 1,2. and 3. Therefore, the referenced Bases discussion and proposed addition of the Note to ITS SR 3.6.1.3.10 are not required to ensure proper interpretation of the requirement and the deletion of the referenced Bases discussion has no impact on safety. In addition, TSB-13 was not issued or approved at the time of the CNS ITS submittal. Therefore, per NRC guidance, the CNS ITS submittal I does not need to include this generic crenge. t

.O ( ) N/I J C.o,.c m.- Smion im, roe.d Ts w Comm.nes w-ITS 3.6.1.4, Drywsli Pressure 3.6.1.4 DOC =JFD ~ CN CORAWIT STATUS 1 Bases ITS B3.6.1.4 Bases - Applicable Safety Analyses See item Number 3.6.1.1-5 2 ITS B3.6.1.4 Bases - REFERENCES See item Number 3.6.1.1-5 NPPD Response: The change, identified in the NRC comment as being incorrect, was inc.cipsisted kito all of the applicable CNS ITS Bases before the Genenc Editorial Change (which proposed the chaage from "NRC Policy Statement

to *10 CFR 50.36(c)f2)(ii)*) being subemtted

% the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that gvice by the NRC in the WNP-2 ITS conversion and is more co< rect than the statements approved by the NRC in other recently approved ITS conversions. The difference between the wording of the Generic Editorial Change and the wordmg of the CNS ITS Bases (with regard to the - reference to 10 CFR SO.36(c)(2)(ii)) is a matter of presentation preference, is consistent with other reference presentations in NUREG-1433, and has no impact on safety. Thefore. NPPD does not consider a revision necessary. i s t l t i . ~. .. -~.

p. ~ ; N O Ceeper Nueteor Semelen bugweved TS Newieur Conunenes se=_o mans ITS 3.6.1.5, Drywes Air Tesupweeme I u.1.si poc A c' ~ comuneNT m: ~ STATUS - 1 Bones ITS 83.6.1.5 Bases - APPUCABLE SAFETY ANALYES See hem Murnber 3.6.1.1-5 l 1-

ITS 83.6.1.5 heen - REFErtENCES s

i, See item Number 3.6.1.1-5 I L NPPD Response: T5 change, identified in the NRC comment as being incorrect, was 'e -o a5 of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from W Policy Statement" to *10 CFR 50.36(cH2:liin being auturutted l ta the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that y;-6 d by the NRC in the WNP-2 ITS - l converen and is more correct then the statements approved by the NRC in other recently +;;- c-d ITS conversions. l xThe difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the j j' reference to 10 CFR 50.36(cH2Hii)) is a matter of presentation preference, is consistent with other reference presentations in NUREG-1433, and has no impact on safety. Therefore, NPPD does not consider a revision necessary. i l:: i i l: s i f i i I I i ? i-l f t I I I f l

O O O me_ew = Cooper Nuclear Station improved T3 Review Comments ITS 3.6.1.6, Low-Low Set (LLS) Vahres 3.6.1.6 DOC -JFD CHANGE /~NFFERENCE ' COMMENT STATUS 1 Bases ITS B3.6.1.6 Bases-APPLICABLE SAFETY ANALYSES See item Number 3.6.1.1-5 1 ITS B3.6.1.6 Bases - REFERENCES See item Number 3.6.1.1-5 The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases NPPD Response: before the Generic Editorial Change (which propused the change from *NRC Policy Statement" to ~10 CFR 50.36(c)(2)(ii)*) bemg submitted te the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is more correct than the statements approved by the NRC in other recently approved ITS conversions. The difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the r ference to 10 CFR SO.36(c)(2)(ii)) is a matter of presentation preference. is consistent with other reference presentations in NUREG-1433, and has no impact on safety. Therefore, NPPD does not consider a revision necessary.

O O O Cooper Nucteer Stasion improved TS Review Comments mr e== ITS 3.6.1.7, Reactor BuiWingC cr : ':-- Chamber Vacuum Breshers 1317.1.7- ' DOC JFD' CHANGE /DFFERENCE CO*M STATUS-1 A.2-2- CTS 4.7.A.3.a Delete this generic change. Bases STS SR 3.6.1.7.2 6 ITS SR 3.6.1.7.2 and Assooated Bases CATS 4.7.A.3.a and STS SR 3.6.1.7.2 required performing a functional test of the each vacuum brealter svery 3 monthst 92 days respectively. ITS 3.6.1.7.2 requires this test in accordance with the IST Program. The justification states that the IST Program requires this test quarterly and therefors is equivalent. However. while the IST program frequency is I currently quarterly, there is n guaranty that it wiR remain quarterly. The staff deems sis change to be generic and lxrfond the scope of review for this conversion. NPPD Response: NPPD will revise the Frequency to be consistent with the CTS (i.e.,92 days). i 1 i i 9 E I ,.-g

M [ Cooper musisor Staden Impsowed TS Rowieur Com sen_a sses 'i

ITS 3.8.1.7, Remeer Bubeng4e-Suppsession Chamber usuu m Bseekers r.sd.76 coc fwo e

~ M CausescePetsuce cosessNT

STATUS'-

s

n..

b.a 2 L1 CTS 3.7.A.3 Provide shocussion and - ITS LCO 3.6.1.7 -. ,Er~:_ i-. for this More i :I ITS 3.6.1.7 ACTIONS and Associated Bases Restrictive change. i CTS 3.7.A.3.a requires to OPERABLE supp ession chamber-1 reactor building vacuum brookers. ITS LCO 3.6.1.7 requires [ each vacuum breaker be OPERABLE. Since there are a total of l 4 reactor building-to-suppression chamber vacuum breakers this change im:resses the number required OPERABLE wacuum i= breakers from 2 to 4. CTG 3.7.A.3.b specifies the ACTIONS to be taken when one of the required two reactor building-to-l suppression chamber vacuum breakers is inoperable. Thu-the - l CTS allows plant operation with 2 vacuum breakers inoperable ' I J and no ACTIONS need to be taken until 3 vacuum breakers i become inoperable. The addition of ITS 3.6.1.7 ACTIONS A ~ I 4 through D require remedial actions be taken as soon as one out t of the four vacuum breakers becomes inoperable. In add".~on, t e the justification (L1) states that the CTS fails to make the j i distinction between :oss of function and loss of redundancy and p. is therefore " unnecessarily conservative.* The staff believes -1 that the CTS is less conservative because of this lack of . distinction.. Thus, the changes associated with L1 are More l I' Restrictive changes rather than Less Restrictive changes. t p. NPPD Response: CTS 3.7.A.3.a considers one vacuum breaker to consist of an air-actuated device and a self-ectuated device. Therefore, I the, umber of devices the Technical Specrfications required OPERABLE is not increased, and NPPD doe > not consider the changes to be ' [ H More Restrictive. I i f 4 f' j .[' N t: i h 3 i h ...u~m.,._...... . -.. ~. ~ ~. ...u.... .-..-....a

O O O Cooper Nucieer Station Improved TS Review On_ a.;. m2_cwm ITS 3- .7, Reactor Bunding-to-Suppression Chamber Vacuum Brookers 3.6.1.7~ DOC -- JFD - CHANGE / DIFFERENCE COMMENT STATUS 3 Bases STS B3.6.1.7 Baces - APPUCABLE SAFETY ANALYSES Either retain the S3 1 ITS B3.6.1.7 Basec - APPUCABLE SAFETY ANALYSES wordmg or provide the i required details in ITS STS B3.6.1.7 Bases - APPUCABLE SAFETY ANALYSES states B3.6.1.7 Bases - that the analytical methods and assumptions involving the APPUCARLE SAFETY reactor building-to-suppression chamber vacuum breakers in the ANALYSES. Provide accident analyses are referenced in the FSAR. ITS D3.6.1.7 additional discussion and Cases - APPUCABLE SAFETY ANALYSES deletes this reference, justification as necessary. and just says that the analytical methods and assumptions are used. The justification used to delete this reference is Bases 1, which is a general justificction. The Bases needs to either describe the methods and assumptions used or provide a reference to where they can be found. The same change is made in ITS B3.6.1.8 Bases - APPUCABLE SAFETY ANALYSIS (See item Number 3.6.1.8-5). NPPD Response: NPPD will revise the Bases to describe the pla.t-specific methods and assumptions for CNS. 4 Bases ITS B3.6.1.7 Bases - AFPUCABLE SAFETY ANALYSES See item Number 3.6.1.1-5 .1 ITS B3.6.1.7 Bases - REFERENCES See item Number 3.6.1.1-5 NPPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from "NRC Policy Statement" to ~10 CFR 50.36(c)(2)(ii)") bemg submitted t3 the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS l conversion and is more correct than the statements approved by the NRC in other recently approved ITS conversions. ]' reference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation prefarence, is consistent with other reference presentations in NUREG-1433, The difference between the wording of the Ger.eric Editor'al Change and the wording of the CNS ITS Bases (with regard to the and has no impact on safety. Therefore NPPD does not consider a revision necessary. [ 4 i-

L.,) G, Cm.) tw c= = Cooper Nuclear Station improved TS Review Comments ITS 3.6.1.7, Reactor Building-to-Suppression Chamber Vac=Jum Brookers COMMENT ' STATUS '3.6.1.7 DOC ~ JFD CHANGE /DfFFERENCE 5 Bases STS B3.6.1.7 Bases - LCO Delete this change. 2 ITS B3.6.1.7 Bases - LCO ITS B3.6.1.7 Bases - LCO extensively modifies for enhanced clarity (Justification Bases 2) STS B3.6.1.7 Bases - LCO. The modifications do not provide enhanced clarity and are j somewhat confusing. The staff would consider this extensive change as generic and beyond the scope of review for this conversion. NPPD will revise the subject ITS Bases wording to match the NUREG-1433 Bases, except will maintain the terms NPPD Response: "v::cuum breaker." instead of the NUREG-1433 Bases terms " butterfly valve," based on plant-specific nomenclature. 6 Bases STS B3.6.1.7 Bases - APPLICABLE SAFETY ANALYSES Either retain the STS 4 ITS B3.6.1.7 Bases - APPLICABLE SAFETY ANALYSES wording, provida plant-specific wording, or STS B3.6.1.7 Bases - APPLICABLE SAFETY ANALYSES appropriate plant specific specifies the five case that were considered in the safety references for each of the analyses to determine the adequacy of the external vat.uum five STS cases or the plant-I breakers. ITS B3.C.1.7 Bases - APPLICABLE SAFETY specific cases. Provide ANALYSES deletes this information entirely. The justification additional disussion and (Bases 4) states that the appropriate analyses are in the UFSAR, justification as necessary. and that the discussion in the Bases is not needed. This is incorrect. The discussion is needed in the Bases to provide a degree of understanding on how these technicas concerns were , addressed at CNS. I NPPD Response: NPPD will revise the Bases to inc,lude any plant-specific cases analyzed for CNS.

C::;x Nucteer Stoelen improved TS Review Comments wr.amase ITS 3.6.1.7,. Reactor Sundng e " . Chamber Vacuum Breshers 63.8.1.7 t DOC fJFD7 ~ CHANGEADNFERENCE 4 CORMIENT w 4 STATUS 4 7 Bases STS B3.6.1.7 Bases - APPLICABluTY Provide additional l 5 ITS B3.6.1.7 Bases-APPUCABluTY justification and discussion l for this delsten beood on - STS 83.6.1.7 Bases - APPUCAB4UTY justifies the operabihty of current licensing bases,. the Reactor Buddeg-to-k---+;:2-. Pool vacuum breakers in. system design or operatenet MODES 1,2, and 3. Two conditions related to excessive constraints.. negative pressure necessitate this MODE Applicabihty, an I inadvertent actuation of the Suppression Pool Spray System and I depressurization of the drywell. ITS B3.6.1.7 Bases APPUCABiUTY states that depressurization of the drywell could t I occur due to inadvertent actuation of the Drywell Spray System. All mention of inadvertent actuation of the Suppression Pool Spray System has been deleted. The ' ? justification does not' adequately address this deletion except l y to say that the major concern is a LOCA inside the drywell. The STS does not differentiate between the two conditions, j since they are both of concem. In addition, if this is such a i major concem why isn't a plant specific LCO proposed for the j. Drywell 3 pray Syrem as was done with Browns Ferry ITS? ] The staff also considers this char.ge to be a potential ge wric -- t i change. In addition, see item Number S3.6.2.4-1. I l NPPD Response:~ The typical vacuum breaker analyses for older BWR/4 plants only looked at a couple of worst-case conditions. Actuation i of drywell spray following a LOCA is one of these conditions. Actuation of suppression pool spray has a very small impact and is not 'l limiting. Also, as far as adding an LCO for Drywell Spray, NPPD does not credit this system with mitigation of any DBA or transient at CNS cnd, therefore, chooses not include it in the CNS ITS (See DOC R.1 for CTS 4.5.A.3.f). The p:W LCO would require the Drywell Spray System to be OPERABLE in order to actuate to mitigate the consequences of a LOCA. The LCO does nothing to preclude actuation of the system, which is actually better from a vacuum breaker calculation point of view. t t i - 5 t i t .r -,4. -m m .m ,s - m - % 4 _....m,. .,m,_ ,,,...m. .m.,

/2 % O O 10: Cooper ph Station improved TS Review Comments wr_caues i ITS 3.6.1.7, Reactor Building-to *r;; =4-. Chamber Vacuum Brookers

3;6.1.7

! DOC' iJFD- / CHANGE / DIFFERENCE ^ COMMENT 1 STATUS ~ 8-None None ' CTS 3.7.A.3 Provide discussion and - ITS 3.6.1.7 and Associated Bases justification for adding the ACTIONS Note. ITS 3.6.1.7 adds a Note to the ACTIONS' stating that separate ' Condition entry is allowed for each liw. The CTS does not contain this allowance. No discussion or justification is provided. NPPD Response: NPPD will revise DOC L1 for ITS 3.G.1.7 to address adding the Note to the Act'Kms. i 1, l P i l l .+ t + l ~ -.. -.. -.

. J[~'~s - d [J Cooper Nucleer Station improved TS Review Comments m.p m CNS ITS 3.6.1.8, Suppression Chamber-to-Drywell Vacuum Brookers 3.6.1.8' DOC 4 LJFD: i CHANGE / DIFFERENCE - COMMENT STATUS-1 A.4 CTS 3.7.A.4.c Correct these I.A.1 CTS 4.7.A.4.d discrepancies. ITS SR 3.6.1.1.2 ' Justification A.4 states that CTS 3.7.A.4.c and 4.7.A.4.d are moved to ITS 3.6.1.1 as ll'S SR 3.6.1.1.2. Justification LA.1 states that the details of CTS 3.7.A.4.c are moved to the Bases. C7 4.7.A.4.d is marked in the CTS markup " Moved to ITS 3.6.1.1: A.4." CTS 3.7.A.4.c in the CTS markup is shown as deleted, with no designations or explanation as in - CTS 4.7.A.4.d. NPPD Response: NPPD will annotate CTS 3.7.A.4.c with both LA.1 and A.4. 2 2 STS 3.6.1.8 RA A.1 Delete this generic ITS 3.6.1.8 RA A.1 change. ITS 3.6.1.8 RA A.1 makes editorial wording changes to corresponding portions of the STS. The justification is that editorial changes are made for consistency. The change is not consistent with other ras, is considered generic, and beyond the scope of review for this conversion. NPPD Response: NPPD will delete the word added to ISTS 3.6.1.8 Required Action A.1, annotated with JFD 2. l

,ph 1 if' Cooper Nucteer Steelon improved TS Review Comments

ww.emuse

- Ces ITS 3.s.1.s. Suppeession Chamber-to-Drywes Vacuum Sponhors t 3M.M DOC "W ~

N<
COWWENT STATUS:

'3' 4 STS SR 3.6.1.8.1 Delete this generic I ITS SR 3.6.1.8.1 and Associated Bases change. STS SR 3.6.1.8.1 requires the vacuum breakers be verified closed every j 14 days and after any descharge or steam or any operation causing a. vacuum breaker to open. ITS SR 3.6.1.6.1 deletes the second frequency (steam or operational opening)..The justification (4) states that this l frequency is not needed since iTS SR 3.0.1 would not be met and ' appropriate actions taken. The justification also states that if conditions exist for the vacuum breakers to be potentially opened, control room : operators would be alerted to the possibehty and would ensure the vacuu.n [. breakers were closed at the completion of the evolution. The SR ' frequency assures that this is done. Further justification for these i i frequenciesfjustifications is that they delay the entering into the l appropriate actions based on statements made in the LCO Bases section (See item Number 3.6.1.8-8). The staff has determmed based on the j justificatiora that this is a generic change which is beyond the scope of f review of a conversion. r l i -k NPPD Response:.The.CNS current licensing basis reflected in the CTS does not include requirements to verify the vacuum breakers cra closed within 2 hours after any discharge of steam or any operat'on causing a vacuum breaker to open. CNS chooses to not include this conditional frequency in ITS SR 3.6.1.8.1. l 1 i I i -f t ll, cw, ~-~ . ~ ~ ~

O O O Cooper Nuclear Ctation improved TS Review Comments we_casme CNS ITS 3.6.1.8, Suppression Chamber-to@rywell Vacuum Breakers 3.6.1.8 ^ DOC: JFD-- CHANGE /DIFFERENCEi COMMENT STATUS '4 5 STS 3.6.1.8.2 Delete this generic Bases ITS 3.6.1.8.2 and Associated Bases change. 1 5 STS SR 3.6.1.8.2 requires a functional test of the vacuum breakers within 12 hours of any discharge of steam into the suppression chamber and following any operation that causes the vacuum breaker to open. ITS SR 3.6.1.6.8.2 deletes these frequencies / conditions. The justification (5) quotes a memorandum from C. E. McCracken to C.I. Grimes, dated 9/8/92, providing the basis for the SR frequency. Thr staff determined that this was su.'ficient justification to retain the frequencies / conditions in Revision 1 to NUREG 1433. The licensee provides additional discusson for deleting these frequencies based on the NRC memorandum. Further justification for these frequencies / justifications is that they delay the entering into the appropriate actions based on statements made in the LCO i Bases section (See item Number 3.6.1.8-8). The staff has determined that this is a generic change which is beyond the scope of review for a conversion. NPPD Response: The CNS current licensing basis reflected in the CTS do include requirements to periodically perform a functional test on the vacuum breakers. However, the CTS do not include requirements to perform functional tests within 12 hours of any discharge of st:am into the suppression chamber and following any operation that causes the vacuum breakers to open. NPPD chooses to not include this conditional frequency in ITS SR 3.6.1.8.2. 4 5 Bases ITS B3.6.1.8 APPLICABLE SAFETY ANALYSES See item Number 3 3.6.1.7-3. See item Number 3.6.1.7-3. NFPD Response: NPPD will revise the Bases to describe the plant-specific methods and assumptions for CNS. I

l o o o Cooper Nucteer Station improved TO Review Comments me.caums CNS ITS 3.6.1.8, Suppression Chamber-to-Drywell Vecuum Brookers 3.6.1.8 ' DOC-JFDL CHANGE / DIFFERENCE - J ' COMMENT STATUS 6 Bases ITS B3.6.1.8 Bases - APPUCA.BLE SAFETY ANALYSES See item Number 3 ITS B3.6.1.8 Bases - REFERENCES 3.6.1.1-5 See Iterr. Number 3.6.1.1-5 NPPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from "NRC Policy Statement" to ~10 CFR 50.36(c)(2)(ii)") being submitted to the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is mere correct than the statements approved by the NRC in other recently approved ITS conversions. The difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the r;ference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference, is consistent with other reference presentations in NUREG-1433, cnd has no impact on safety. Therefore, NPPD does not consider a revision necessary 7 Bases ITS B3.6.1.8 Bases - APPLICABILITY See item Number 4 3.6.1.7-7 and Bases See item Numbers 3.6.1.7-7 and S3.6.2.4-1. S3.6.2.4.1 6 NPPD Response: The typical vacuum breaker analyses for older BWR/4 plants only looked at a couple of worst-case conditions. Actuation of drywell spray following a LOCA is one of these conditions. Actuation of suppression pool spray has a very smallimpact and is not limiting. _ Also, as far as adding an LCO for Drywell Spray, NPPD does not credit this system with mitigation of any DBA or transient at CNS y end, therefore, chooses not include it in the CNS ITS (See DOC R.1 for CTS 4.5.A.3.f). The proposed LCO would require the Drywell Spray System to be OPERABLE in order to actuate to mitigate the consequences of a LOCA. The LCO does nothing to preclude actuation of the system, which is sctually better from a vacuum breaker calculation point of view.

.g \\ " ~ Cooper Nuclear Station impioved TS Review Comments , m e_ena m CNS ITS 3.6.1.8, Suppression Chamber-to-Drywell Vacuum Breakers - ~3;611;8 DOC; JFD CHANGE / DIFFERENCE ? ' COMMENT STATUS 8-Bases STS B3.6.1.8 Bases - LCO Retum the words 5 ITS B3.6.1.8 Bases - LCO. "during testing or" to ITS SR 3.6.1.8.1 the LCO Bases section. f The LCO Bases for STS 3.6.1.8 requires the vacuum breakers to be closed except during testing or when performing their intended function. ITS B3.6.1.6 Bases LCO deletes the exception for "during testing or." iTS SR i 3.6.1.6.1 verifies that the vacuum breakers are closed. ITS SR 3.6.1.6.1 has a Note associated with it that provides an exception during surveillance testing. The deletion of phrases "during testing or" from the LCO Bases section negates the Note. It should be noted that the same phrase is retained in ITS B3.6.1.7 Bases - LCO. NPPD Response: NPPD will revise the LCO Bases section as suggested in the comment. l

p N' W h h W TS Review h ~ =_m ITS 3.6.2.1, Suppreselon Peel Average _Tempermesse i 3.d1' DOC inf -M3" 4 CtWUeGEDEFBIGOCE -M enmaassaur fgyAf g 4: 4 E1-L.2 - 2 - CTS 3.7.A.1.c Delete this generic Renae CTS 3.7.A.1.d change. See item . '4 [ CTS 3.7.A.1.e Number 3.6.2.1-3. STS LCO 3.6.2.1. 1STS 3.6.2.1 ACTIONS and Associated Bases ITS LCO 3.6.2.1 ITS 3.6.2.1 Condition A - ITS 3.6.2.1 RA B.1 ITS 3.6.2.1 Condition C and Associated Bases L CTS 3.7.A.1.c requires a maximurn suppression pool temperature of 95'F during normal power operation. CTS 3.7.A.1.d requires a maximum suppression pool temperature of 105'F during testing which adds heat to the suppression pool. CTS 3.7..A.1.e scrams the reactor when the suppression pool temperature reaches 110*F. STS LCO 3.6.2.1.a. i L requires a suppression pool average temperature be s 95'F when any OPERABLE intermediate range monitor (IRM) channel is 2' 25/40 divisions of full scale on Range 7, while STS LCOs 3.6.2.1.b and c require a. j suppression pool average temperature be s 105* F when any IRM channel j. 2 25/40 divisions on Range 7 and s 110*F when all IRM channels are s. i 25/40 divisions on Range 7.- ITS 3.6.2.1 changes the IRM criteria in both j the LCO and ACTIONS to.1% RTP. Both STS B3.6.2.1 Bases LCO and - justification 2 state that 1% RTP is not readdy quantified with much accuracy. However, the Baises states that 25/40 divisions of full scale on IRM R_ange 7 is a convenient measure of when reactor is providing power - essentially equivalent to 1% RTP. Since 1% RTP cannot be readily - quantified with much accuracy the STS specifies an acceptable means to 'I determine this. Therefore, the staff finds the ITS change unacceptable i and generic. See item Number 3.6.2.1-3. q NPPD Response:_ NPPD has identified this change to the NRC Project' Manager for CNS as a beyond-scope change and should be i,.c-: :::I cs such (i.e., provided to the NRC Containment Systems Branch for review). s m

+t 4 D C::;:: ph Stadon improved TS Review Comments .sen_ - ITS 3.6.2.t Suppression Peel Average Tempereewe 3.6.2.1~ DOC QFD CHANGEtDIFFERENCE ' COGNIM!In & iSTATUS: ~ 2' L3 CTS 4.7.A.1.c Provide addstional 4 ama

and CTS 4.7.A.1.c requires an extemal visual inspection of the suppression justdication to show chamber whenever there is indication of relief valve operation with the.

that NEDO-30832 j local suppression pool temperature reaching 160*F or greater. L3 states hos been reviewed 1 that ITS 3.6.2.1 does not retain this CTS requirement in accordance with and approved by the ' NEDO-30832. " Elimination of Limit on BWR Suppression Pool staff and its L Temperature for SRV Discharge with Quenchers," dated December 1984. - applicabihty and/or - The discussion and justification do not indicate if NEDO-30832 has been : acceptance by the - reviewed and approved by the staff. It also does not indicate its staff for use as CNS. applicability to CNS. This item may be considered a beyond scope of review item for this conversion since its applicability to CNS may not 1 have been approved by the staff.

l d

NPPD Response: The SRV discharge quenchers were not part of the original design at CNS and were subsequently installed in 1980c is CTS 4.7.A.1.c was included in the CNS CTS in 1975. 4 t i 3 The requirements of NUREG-1433 (Revision'O and Revision 1) were developed based on NEDC-31681, *BWR Owners' Group improved BWR Technical Specifications," dated 1989. In Volume 4 (Standard Technical Specifications Comparison) to NEDC-31681, markups of ~ j Standard Technical Specifications (NUREG-0123) and discussions were provxied. NUREG-0123 surveillance 4.6.2.1.c required performing ~ cn external visual examination of the suppression chamber after safety / relief valve operation with the suppression chamber average water ( j t:mperature greater than or equal to 160*F and the reactor coolant system pressure greater than 200 psig. This requwement was deleted ~ ) from the NUREG-0123 during the conversion to NUREG-1433. The basis for this deletion, as discussed in NEDC-31681, is that " j NEDO-30382, " Elimination of Limit on BWR Suppression Pool Temperature of SRV Discharge with Quenchers," dated December 1984 ' I demonstrated that there were no undue loads on the suppression pool or its components from SRV discharges through quenchers at j clavated pressures and temperatures and therefore there was no need to perform this visual examination. CTS 4.7.A.1.c requires an equivalent visual inspection and was put in place during the original licensing of CNS. The CNS SRV discharge lines did not have installed - quencher devices when the plant was originally licensed. Therefore, this change is considered to be part of the ITS conversion and should be processed as such. I i

h

{ ~ - )

O O O - Cooper Nuclear Station improved TS Review Comments u n_c= m s ITS 3.6.2.1, Suppression Pool Average Temperature 23-6.2.1 DOC DJFD-CHANGE / DIFFERENCE ~ ' COMMENT STATUS 3 2 CTS 3.7.A.1.c Provide additional Bases CTS 3.7.A.1.d discussion and 4 CTS 3.7.A.1.e justification for this ITS LCO 3.6.2.1 Less Restrictive ITS 3.6.2.1 ACTIONS A, B, and C and Associated Bases change. See item Number 3.6.2.1-1. CTS 3.7.A.1.c requires a maximum suppression pool temperature of 95'F during normal power operation. CTS 3.7.A.1.d requires a maximum suppression pool temperature of 105* during testing which adds heat to the suppression pool. CTS 3.7.A.1.e scrams the reactor when the suppression pool temperature reacher 110*F. ITS LCO 3.6.2.1.a requires suppression pool average temperature is s 95'F with THERMAL POWER 21% RTP and performing no testing that adds heat to the suppression pool. ITS LCO 3.6.2.1.b requires suppression pool average temperature s 105"F with THERMAL POWER 21% RTP and testing that adds heat to the suppression pool. ITS LCO 3.6.2.1.c requires the suppression pool average temperature s 110* F with Thermal Power s 1% RTP. Adding a specific THERMAL POWER level limits to these CTS LCOs is a Less Restrictive change and was not discussed and justified. See item Number 3.6.2.1-1. NPPD Response: NPPD has identified this change to the NRC Project Manager for CNS as a beyond-scope change and should be processed as such (i.e., provided to the NRC Containment Systems Branch for review). 4 Bases ITS 3.6.2.1 Bases - APPLICABLE SAFETY ANALYSES See Item Number 3 ITS B3.6.2.1 Bases - REFERENCES 3.6.1.1-5 See item Number 3.6.1.1-5 l NDPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from *NRC Policy Statement" to "10 CFR 50.36(c)(2)(ii)*) being submitted + to the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by tive NRC in the WNP-2 ITS conversion and is more correct than the statements approved by the NRC in other recently approved ITS conversions. The difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the rsference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference. is consistent with other reference presentations in NUREG-1433, cnd has no impact on safety. Therefore, NPPD does not consider a revision necessary.

1' o o o ,a Cooper Nucteer Station improved TS Review Comments sen_casses ITS 3.6.2.1, Suppression Pool Average Temperature l-3.6.'2.1 DOCL 'JFD 4 CHANGE / DIFFERENCE COMMENT

STATUSl 1

l 5 Bases STS B3.6.2.1 Bases - RA D.1.D.2 and D.3 Correct this 5 ' ITS B3.6.2.1 Bases - RA D.1, D.2 and D.3 discrepancy i STS B3.6.2.1 Bases - RA D.1, D.2 and D.3 states the following: "Given the high suppressson pool average temperature in this Condition..." ITS B3.6.2.1 Bases - D.1, D.2, and D.3 decapitalizes the "C"in " Condition" and justifies it as a typographical error. This is incorrect..The condition referred to is Condition D. Therefore, it should be " Condition" rather than ." condition " NPPD Response: NPPD will delete this change in a revision to the CNS ITS submittal. However, note that the NUREG-1433 Bases are - inconsistent in the treatment of this term. This same term used in the same manner was found to be both " Condition" and " condition" in the various Bases sections. 6 CTS 3.7.1.c.d.e, and f. Provide additional .lTS LCO 3.6.2.1 discussinn and ITS 3.6.2.1 ACTIONS A, C, D, and 1 justification regarding whether the CTS and CTS 3.7.1.c, d, e, and f specify temperature limits that are exprecsed as ITS are equivalent in i " temperature" without specifying whether the temperature is an average how temperature for the suppression pool or a single temperature measurement. limits are specified. ITS LCO 3.6.2.1 and ACTIONS 3.6.2.1 A. C, D, and E specify the temperature limits as " average temperature." No discussion or justification is provided to indicate that the CTS and ITS are equivalent. NPPD Response: NPPD will write an A DOC stating that the change is consistent with current CNS plant practice. i i I t I m ..._m-m___. .-m_....

p m m man.com Cooper Nuclear Ctation improved TS Review Comments ITS 3.6.2.2, Suppression Pool Water Level COMMENT STATUS' CHANGE / DIFFERENCE 3.6.2.2 DOC-JFD Revise the CTS 1 - A.2 CTS 3.7.A.1 markup to indicate L1 ITS 3.5.2 that the change CTS 3.7.A.1 specifies that at any time the nuclear system is pressurized or "except as specified its...and 3.5.f.5." is work is being done which has the potential to drain the vessel (OPDRVs) an Administrative - the suppression pool water level shall be within limits except as specified in CTS 3.5.F.5. The applicability that deals with OPDRVs has been moved change (A.2). to ITS 3.5.2 by justification A.2 which is acceptable. The exception for CTS 3.5.F.3 is also moved to ITS 3.5.2 but it is justified by an L1. L1 states that this is an Administrative Change'that deals with OPDRVs. The staff agrees that the change is Administrative not Les. Restrictive and believes that justification A.2 is the appropriate change designation. The elimination of the minimum suppression pocilevel requirements in MODES 4 and 5 is an Administrative change NPPD Response: (since ITS 3.5.2 duplicates them). However, the elimmation of the maximum suppression poollevel requirements in MODES 4 and 5 is a Less Restrictive change and is more appropriately addressed in this section, since ITS 3.5.2 does not include limits on maximum suppression pool water level. ITS B3.6.2.2 Bases-APPLICABLE SAFETY ANALYSES Seo item Number 2 Bases 3.6.1.1-5 3 ITS B3.6.2.2 Bases - REFERENCES See item Number 3.6.1.1-5 The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases NPPD Response: before the Generic Editorial Change (which proposed the change from "NRC Policy Statement" to "10 CFR 50.36(c)(2)(ii)") being submitted to the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is more correct than the statements approved by the NRC in other recently approved ITS conversions. The difference between the woroing of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the reference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference, is consistent with other reference presentations in NUREG-1 rnd has no impact on safety. Therefore, NPPD does not consider a revision necessary. (

..;r.4 Juni 4 -- % J ) E 4 6 4 m ih4 -w v --+'=e. m - I s-. a. 6 i.. O Cooper >=4==r Stadon improved TS Review Comments sees. - s - ITS 3 8.2.3, Residual Heat Removal (Rift) Suppreselon Pool CoeAng l l cnaamasa4 - 5STATUSi l 2 3.8.2' 3 i ' DOC" 1JFDi CHANGElDIFFERENCE L L L1 M.1 '1 STS 3.6.2.3 ACTION B Delete this j l-Bases ITS 3.6.2.3 ACTIONS B and C and Associated Bases. genonc -l L -4 change. L" STS 3.6.2.3 ACTION B requives a shutdown if the ras and associated Completion T' nes are not met and for two RHR Suppression Pool Coolmg l w subsystems inoperable (loss of function). ITS 3.6.2.3 brsaks STS '3.6.2.3 l[ ACTION B up into two ACTIONS - ACTION B - two subsystems inoperable (loss. of function) and ACTION C - ras and Completion Tunes not met. ' ACTION B instead of requiring a shutdown per the STS, requires the restoration of one RHR ' subsystem to OPERABLE stat su within 8 hours. The justification used (1) l provides a number of reasons to allow this change. In addition, other BWR/4 conversions have proposed this saae change using the stated reasons as well as l others. In all casesi the staff finds that total loss of RHR Suppression Pool r Cooling requires an immediate shutdown. It is the staff's understanding that this t change was submitted to the OGs as a TSTF and was rejected. Therefore, the l change is unacceptable and is considered a generic change that is beyond the scope of review for this conversion. NPPD Response: A generic change has been submitted to the NEl TSTF for processing. This change has not been rejected. l i 2 Bases -ITS B3.6.2.3 Bases - APPUCABLE SAFETY ANALYSES See item

j 2.

ITS B3.6.2.3 Bases REFERENCES See item Number 3.6.1.1-5. j NPPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into' all of the soplicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from "NRC Policy Statement" to "10 CFR 50.36(c)(2)(ii)") being autmutted ta the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS m conversion and is more currect than the statements approved by the NRC in other recently approved ITS conversions. 1 - The difference between the wording of the Genenc Editorial Change and the wording of the CNS ITS Bases (with regard to the reference J ts 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference, is consistent with other reference presentations in NUREG-1433, and has 'f no impact on safety. Therefore, NPPD does not consider a revision necessary. .f l

( ,m nn.c= sus Cooper Nuclear Station improved TS Review Comments l ITS 3.6.2.3, Residual Heat Removal (RHR) Suppressio Pool Cooling -3 6.2.3 DOC -JFD CHANGE / DIFFERENCE ' COMMENT STATUSo Correct this 3 Bases STS B3.6.2.3 Bases - RA A.1 l 3 ITS B3.6.2.3 Bases RA A.1 discrepancy. STS B3.6.2.3 Bases - RA A.1 states the fellowing: "In this Condition, the remaining RHR..." ITS B3.6.2.3 Bases-RA C.1 decapitalizes the letter "C* in l l " Condition". This is incorrect. The sentence is referring to Condition A: therefore, tl:e "C" in " Condition" should be capitalized. NPPD will delete this change in a revision to the CNS ITS submittal. However, note that the NUREG-1433 Bases are NPPD Response: inconsistent in the treatment of this term. This same term used in the same manner was found to be both " Condition" and " condition the various Bases sections. 4 Bases STS B3.6.2.3 Bases - SR3.6.2.3.2 Provide j 6 ITS B3.6.2.3 Bases - SR 3.6.2.3.2 additional l discussion STS B3.6.2.3 Bases - SR 3.6.2.3.2 states that the inservice inspections of the and RHR Pump trend performance. ITS B3.6.2.3 Bases - SR3.6.2.3.2 deletes the justification reference to performance trending. The justification states that the change is for this revised to be consistent with the specifications. This justification is inadequate change. and does not apply in this case. The CNS IST Program does trend RHR pump performance. NPPD will revise the CNS ITS submittal to use the STS words. NPPD Response: 5 Bases ITS B3.6.2.3 Bases - LCO Delete this generic 7 l A paragraph has been added to ITS B3.6.2.3 Bases-LCO which discusses RHR change. OPERABILITY in Mode 3 when below tl.a actual RHR shutdown cooling permissive pressure. The justification used (Bases 7) states that the addition is an editorial change for clarity. The change is not an editorial clarity change, but a technical change. As such, the staff finds the change to be generic and beyond the scope of review for this conversion. NPPD Response: NPPD will delete the subject phrases.

O O O Cooper Nuclear Station improved TS Roiew Comments s e.c=s m STS 3.6.2.4, Residual Heat Removal (RHR) Suppression Pool Spray S3.6.2.41 DOC-JFD' ~ CHANGE /DOFFERENCE COMMENT JSTATUS 1 R.1 1 CTS 3/4.5.A Include CTS 3/4.5.A Bases STS 3.6.2.4 and Associated Bases in ITS 3.6. Provide 1 additional discussions CTS 3.5.A specifies the OPERABlUTY requirements for the Core Spray and justifications for and LPCI Systems. CTS 4.5.A.3 specifies the surveillance required to any changes made to determine Drywell and Suppression Pool Spray System OPERABILITY - the CTS /STS. RHR pump tests (CTS 4.5.A.3.b and d) and air test of spray header (CTS 4.5.A.3.f). STS 3.6.2.4 specifies the OPERABIUTY requirement for the RHR Suppression Pool Spray. ITS 3.6. does not include STS 3.6.2.4 based on the premise (R.1) that CTS 4.5.A.3.f does not meet the Criterion specified in 10 CFR 50.36(c)(2)(ii). This justification is incomplete in that it does not address the other aspects of the RHR Suppression Pool Spray System and Drywell Spray System encompassed by CTS 3/4.5.A. In addition, the staff has determined and stated in the Bases of STS B3.6.2.4 that the RHR Suppression Pool Spray System does meet Criterion 3 of 10 CFR 50.36(c)(2)(ii). Since this system was in the CTS and the staff determination is that it meets Criterion 3, this specification should be included in the ITS. However, STS 3.6.2.4 of NUREG-1433 may not be the appropriate TS in the CNS case STS 3.6.1.7 "RHR Containment Spray System

of NUREG-1434 (BWR-6) may be the more appropriate TS to use. Also, consideration should be given to adding a separate LCO for Drywell Spray System.

See item Number 3.6.1.7-7. NPPD Response: The NRC Staff's evaluation that concluded that RHR Suppression Pool Cooling System did meet Criterion 3 of 10 CFR 50.36(c)(2)(ii) was based on the fact that the BWRs included in the eva!uation take credit for the system to mitigate the consequences of a DBA. In addition, the drywell and torus spray headers do not support the OPERABILITY of Core Spray or LPCI. Since drywell and torus spray are not credited with mitigating the consequences of DBA or transients at CNS and do not meet any of the other criteria in 10 CFR 50.36 (c)(2)(ii) at CNS, NPPD finos it inappropriate to include these requirements or add any other requirements related to the drywell and torus spray headers to the CNS ITS. 1 e

O O O ses*c-s ms Cooper Nuclear Station improved TS Review Comments ITS 3.6.3.1, Primary Containment Oxygen Concentration 3 6.3.1 DOC JFD CHANGE / DIFFERENCE COMMENY STATUS See item l 1 1 STS 3.6.3.3 Number Bases ITS 3.6.3.1 S3.6.3.2-1. 4 The change in numbering from STS 3.6.3.3 (Primary Containment Oxygen Concentration) to ITS 3.6.3.1 will depend on the resolution of item Number S3.6.3.2-1 NPPD Response: No response required. NPPD considers this comment to be for internal NRC issue tracking purposes. 2 Baces STS B3.6.3.3 Bases - BACKGROUND See item 1 ITS B3.6.3.3 Baser BACKGROUND Number S3.6.3.2-1. STS B3.6.3.3 Bases - BACKGROUND refere x.es certain STS LCO one of which is STS LCO 3.6.3.2 *0rywell Cooling System Fans". The iTS deletes this reference l based on the justification that STS 3.6.3.2 is not included in the CNS ITS. This deletion will depend on the resolution of item Number S3.6.3.2-1. 1 NPPD Response: No response equired. NPPD considers this comment to be for internal NRC issue tracking purposes. 3 Bases ITS 83.6.3.1 Bases - APPLICABLE SAFETY ANALYSES see hem 2 ITS B3.6.3.1 Bases - REFERENCES Number 3.6.1.1-5. j See item Number 3.6.1.1-5. t NPPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (.vhich proposed the change from "NRC Policy Statement" to 10 CFR 50.36(c)(2)(ii)") being submitted to the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is more correct than the statements approved by the NRC in other recently aproved ITS conversions. The difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the reference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference, is consistent viith other reference presen".etions in NUREG-1433, rnd has no impact on safety. Therefore, NPPD does not consider a revision necessary.

~ Cooper Nucteer Stedon improved TS Review Comments

sese.c=ames STS 3.6.3.2, Drywes Coodne System Fans S3;63.22 DOC MJFD '

" ~ CHANGElDIFFERENCE COMMBff^ 7 TATUS) i S 91 <1 STS 3.6.3.2 and Associated Bases - Provide additional 7 1 STS 3.6.3.2 specifies the requirements and survesilences for Drywe81 justification for this - 1 Coolmg System Fans.' The ITS does not contain this speafication. The deletion based on '[ justification (1) used states that CNS does not assume Drywell Cooling current licensing System Fans are available to assure adequate mixing. STS B3.6.3.2 bases, system design Bases APPUCABLE SAFETY ANALYSES states that even though no credit or operational L

j for mechanical mixing is assumed in the analysis, the system does meet constraints.

Criterion 3 of 10 CFR 50.36(c)(2)(ii), for other reasons. NPPD Response: The Applicable Safety Analysis section of the Bases for ISTS 3.6.3.2, "lDrywell Coolmg System Fans)," says that. the Drywell Cooling System provides the capability to reduce the local hydrogen concentration to appioximately the bulk average - concentration following a DBA. The Appiicable Safety Analysis section of the ISTS Bases also says that the IDrywe'l Coolmg System fansl. cra tequired to keep thn drywell cool during MODES 1 and 2. At CNS, the combustible gas control analysis does not assume drywell cooling fans operate to assure adequate mixing of the drywell of the drywell atmosphere. The requirement to maintain the drywell within the initial temperature assumptions of the primary containmsnt = enalysis is adequately' controlled by ITS 3.6.1.5, "Drywell Air Temperature.* : In addition, the CNS current licensing basis, as reflected in < the CTS, does not include requirements for drywell cooling fan OPERABluTY. Therefore, consistent with the current lictnsing basis,' ' '[ l NPPD will not include the requirements of ISTS 3.6.3.2 in the CNS ITS. I t li

7 1

4 4 4 4 i.e..,;-- w- ~~.s a w .m, c n.u ..e e . ~ - *.+- v.,-- , - +.. -, +~nm ~+.c ~v-- ~-:----

g O ( V Cooper Nuclear SDation improved TG Review Comments sen.c uws ITS 3.6.4.1, Secondary Containment 3-6.4.1' DOC: 'JFD-CHANGE / DIFFERENCE ' COMMENT -STATUS 1 A.5 4 CTS 1.0.V iTS 3.6.4.1 Revise the CTS markup A.13 3ases 1 CTS 3.7.C.1 ITS 3.6.4.2 of ITS 3.6.4.1, 3.6.4.2, M.6 Bases 5 CTS 3.7.B.1 ITS 3.6.4.3 and 3.6.4.3 to include a markup of CTS 1.0.V CTS 1.0.V defines Secondary Containment Integrity. A markup and provide additional of CTS 1.0.V is provided in the CTS markup of ITS 1.0, but not in discussion and the CTS markups of ITS 3.6.4.1, 3.6.4.2 and 3.6.4.3. justification for these Justification A.5 in the CTS markup of FS 3.6.4.1 and 3.6.4.2 Administrative changes. and justification A.13 in the CTS marh; of ITS 1.0 both state See item Numbers that the definition of Secondary Containment Integrity is deleted 3.6.4.1-4, 3.6.4.2-2 and from the ITS. This is incorrect. The details of the definition with 3.6.4.3-2. regard to 1.0.V.1 is encompassed by ITS SR 3.6.4.1.3,1.0.V.2 is encompassed by ITS LCO 3.6.4.3 and 1.0.V.3 is encompassed by ITS LCO 3.6.4.2, ITS SR 3.6.4.2.2 and ITS SR 3.6.4.2.3. These Administrative changes either have not been justified, or are characterized as More Restrictive changes. See item Numbers 3.6.4.1-4, 3.6.4.2-2 and 3.6.4.3-2. NPPD Response: NPPD will revise the CNS ITS submittal to address the comment. 2 M.4 CTS 3.7.C.1 Revise the CTS markup l CTS 3.7.C.1.e.b to include these More ITS 3.6.4.1 APPUCABluTY Rest.ictive changes. See ITS 3.6.4.1 ACTION C ltem Number 3.6.4.1-3. Justification M.4 states that a new APPUCABlUTY is proposed to be a.'ded to CTS 3.7.C.1 (ITS 3.6.4.1) and a cor.asponding Condition (ITS 3.6.4.1 Condition C) and Required Actions (ITS 3.6.4.1 RA C.3) for Operations with the Potential for Draining the Reactor Vessel (OPDRVs). The CTS markup does not show these changes and the M.4 change that is shown (CTS 3.7.C.1.e.b) has nothing to do with these changes. See item Number 3.6.4.1-3. NPPD Response: On CTS markup page 2 of 2, NPPD will show the M.4 annotation applies to the term "OFDRVs* added in approximately the middle of the left hand margir of the page. NPPD will also revise DOC M.4 to appropriately use the acronym fo< proper communication.

n y Cooper Nuclear Station Improved TS Review Comments an_c=sms - ITS 3.6.4.1, Secondary Containment 3-6.4.1 DOC-JFD' CHANGE / DIFFERENCE COMMENT STATUS-3 M.4 CTS 3.7.C.1.e.b Revise the CTS rnarkup ITS 3.6.4.1 RA C.1 Note to shcw this ci ange as an Adrninistrative CTS 3.7.C.1.e.b specifies the remedial actions for an inoperable change and provide secondary containment when moving irradiated fuel or during occussion anr1 core alterations. A statement is provided in CTS 3.7.C.1.e.b that jus ification for this the provisions of CTS 1.0.J are not applicable. CTS 1.0.J is the Administrative change. shutdown requirement of the CNS TS. T he CTS markup shows this as becoming ITS 3.6.4.1 RA C.1 Note *LCO 3.0.3 is not applicable" and is designated M.1. ITS LCO 3.0.3 and CTS 1.0.J are basically the same requiremt r t. Thus the ITS 3.6.4.1RA C.1 Note and the CTS statement on 1.0.J are the same. Thus, the change is an Administrative change, rather than a More Restrictive change. See item Number 3.6.4.1-2. NPPD Response: For movement of irradiated fuel in secondary containment during MODE 4 or % the chmge is Administrative. However, if irradicted fuel were moved in secondary containmer.t during MODE 1, ?, or 3, then LCO 3.0.3 would apply. The clarification the Note provides is necessary because defaulting to ITS LCO 3.0.3 (during irradiated fuel assembly movement in MODE 1,2, or 3) would require a rc ctor shutdown, but would not require immediate suspension of movement of irradiated fuel assemblies when required corpponents are inoperable. ITS LCO 3.0.3 is only applicable in MODE 1,2, or 3. Therefore, once the unit has been placed in MODE 4 in awardance with ITS LCO 3.0.3. ITS LCO 3.0.3 is no longer applicable. ITS 3.6.4.1 Required Action C.1, which requires susper.sion of irradiated fuel

r. 7vement, would then be applicable. However, the requirements of ITS LCO 3.0.3 would allow up to 37 hours to place the unit in MCOE 4 (and '.s a result would allow up to 37 hours to suspend ifradiated fuel movement). Therefore, with the unit in this Condition, the Note, "LCO 3.0.3 is not applicable," ensures there is no postponement of the actions for requi.ing immediato suspension of movement of irradiated fuel assemblies due to entry into ITS LCO 3.0.3 and the immediate placement of the unit in a condition of minimum risk, with r:spect to fuel handling activities during MODE 1,2, or 3. Therefore, NPPD will provide an M DOC for thi channa.

i

O O O se.v.c=s m Cooper Nuclear Station Improved TS Review Comments ITS 3.6.4.1, Secondary Containment = ' COMMENT STATUS CHANGE / DIFFERENCE - 3 6.4.1 DOC -JFD Delete the TSTF 18 4 M.6 4 CTS 1.0.V.1 STS SR 3.6.4.1.3 and Associated Bases changes or provide Bases additional discussion and ITS SR 3.6.4.1.3 and Associated Bases 1 justifi;ation for the Bases deviations from the STS. 5 STS SR 3.6.4.1.3 verifies that the secondary containment access doors are closed except when it is being used foi entry or exit, then at least one door shall be opened. ITS SR 3.6.4.1.2 and its associated Bases modifies STS SR 3.6.4.1.3 and its associated Bases based on CTS 1.0.V.1 and TSTF 18. TSTF 18 has been rejected by the staff. The reason for the changes in ITS 3.6.4.1.3 and the associated 9ases is maintenance of the CNS current licensing basis reflected in the CTS definition of Secondary Containment Integnty (CTS 1.OV). NFPD does not choose to adopt the ISTS SR 3 NPPD Response: l requirement to maintain two doors closed in each secondary containment cccess opening. (The first full sentence in the section should end with " closed.") Prr <ide additional 5 LA.2 ITS CTS 4.7.C.1.c l discussion and B3.6.4.3 ITS B3.6.4.3 Bases - BACKGROUND justifir ation for this Less Baset 1 CTS 4.7.C.1.c specifies details regarding wind inditions when Restrictive change. verifying Secondary Containment integrity. These details (calm wind between 2 and 5 mph) are not included in ITS SR 3.6.4.1.4. The justification (LA.2) states that the oesign details are mcved to the Bases for ITS 3.6.4.3. However, ITS B3.6.4.3 Bases - BACKGROUND states that wind conditions are " neutral wind conditions" which the staff defines as *O mph," which is a Less Restrictive chme. NPPD will revise the Bases to provide details similar to CTS 4.7.C.1, but to reflect the CNS USAR Section V-3.3.4 NPPD Response: (ITS B3.6.4.3 Reference 2) definition of neutral wind conditions as >2 mph and <5 mph. .m.

+ u ) Ceeper Nucteer Seedon leproved TS Review Comments seei_tmamos b . ITS 3.6.4.1, E+::--i-, Cenesinment, ^ ~ .t 1 I 3.8.421< 5DOCt YJFDi CHANGEJDFFERENCE i """N* "ESTATUSI '^

: Bases ~

ITS B3.6.4.1 Bases - AF.N SAFETY ANALYSES - - See hem Number 3~ ITS B3.6.4.1 Bases - REFERENCES - 3.6.1.1 -5.' +i j See item Number 3.6.1.1-5. ] [. NPPD Response: The change, identified in the NRC comment as being incorrect, was incorporated into'all of the applie=Ma CNS TTS Beses q L before the Generic Editorial Change (which prc, posed the c.hange from "NRC Policy Statement

to ~10 CFR SO.36(cH2Hii)") being submitted to the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS L

~I l conversion and is more correct than the statements approved by the NRC in other recently app-oved ITS conversions. L L The difference between the wo. ding of the Generic Editorial Change and the wordirig of the CNS ITS Bases (with regard to the p reference to 10 CFR 50.36(c)(2)(ii)) is a matter of preseritation preference, is consistent with other reference presentations in NUREG-1'433, and has no impact on safety. Therefore, NPPD does not consider a revision necessary. 7' . Bases ITS B3.6.4.1 Bases - SR 3.6.4.1.1 Provide additional-4 discussior and.' The following statement is added to ITS B3.6.4.1 Bases - justification for.this =3 SR 3.6.4.1.1: " Momentary transients on the installed... failure techn%al change. j ' ~ to meet this SR." The justification used (Bases 4) to add this- { statement is an editorial clarity justification. This justification is inadequate for this technical change, which is not specified in q t the CTS. l 1 NPPD Response: NPPD will delete the' subject phrase. .j i ]. , i p f .- -.~ ..-- ~-.- 1

p (x s .( ,) ~ L j' Cooper Nuclear Station improved TS Review Coinments m i_ cme m ITS 3.6.4.1, h-- f - -y Containment 3.6.4.1: IDOCi

JFD1 CHANGE / DIFFERENCE -

COMMENT ' STATUS .8 CTS 3.7.C.1.e Provide a discussion and ITS 3.6.4.1 ACTION C justification for this More Restrictive change. i CTS 3.7.C.1.e requires the restoration of secondary containment integrity within 4 hours or suspend fuel handling operations and core alterations. IT5 3.6.4.1 ACTION C requires it e immediate suspension of fuel handling, core alterations and OPORVs with no time is allowed to restore secondary containment. Thus ITS 3.6.4.1 ACTION C is More Restrictive than CTS 3.7.C.1.e. No discussion or justifications are provided for this More Restrictive change. NPPD Response:- NPPD will provide an M DOC for this change. 4 ) f ~.

4 df% Y x l O %) 'N) l-Cooper Nucteer Station improved TS Review Comments , mm c=ues l' ITS 3.6.4.2, Secondary Conta!nment isolation Vabes (SCIVsl l 3.6.4.2' ! DOC 2 BJFD' CHANGE /DfFFERENCE - ~ COMMENT -STATUS i l -1. A.4 CTS 3.7.C.1 Provide a l. ITS 3.6.4.2 ACTION Note 2 discussion and justification for this A new Note is proposed to be added to CTS 3.7.C.1 as proposed Less Restrictive ITS 3.6.4.2 Note 2. Note 2 provides explicit instructions (separate change. Condition entry for each flow path) for the proper application of the ACTIONS for TS compliance. This change is classified as an Administrative change that is consistent with the mtent of the CTS ACTIONS for inoperable secondar*; containment isolation valves. This justification is incorrect.. The wording of CTS 3.7.C.1 and in particular CTS 3.7.C.1.e does not convey the implicit or explicit instructions to allow reparate Condition entry for each secondary containment flow path. Thus the addition is considered as a Less Restrictive change. NPPD Response: NPPD will revise DOC L2 for ITS 3.6.4.2 to address the addition of Note e to the ITS 3.6.4.2 ACTIONS. 2 A.5 CTS 1.0.V.3 ITS SR 3.6.4.2.2 See item Number A.13 CTS 3.7.C.1 ITS SR 3.6.4.2.3 3.6.4.1-1. M.5 ITS LCO 3.6.4.2 See item Number 3.6.4.1-1. NPPD Response: NPPD will revise the CNS ITS submittal to address the comment.

Cooper Nuclear Station improved TS Review Comments mm.cmas. ITS 3.6.4.2, Secondary Containment isoleelon Valves (SCIVsl I ~ 3.6.4[2$ l DOC ; W ' CHANGE / DIFFERENCE > .COlmIENT ' STATUS '3 Bases ITS B3.6.4.2 Bases -' APPUCABLE SAFETY ANALYSES See item Number i .1 ITS B3.6.4.2 Bases - REFERENCES. 3.6.1-1-5. See' Item Number 3.6.1.1-5.- NPPD Resp mse:: The change, identified in the NRC comment as being incorrect, was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from "NRC Policy Statement" to "10 CFR 50.36(c)(2)(ii)*) being submitted to the NRC in its current form.' The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the Wi4P-2 ITS conversion and is more correct than the statements approved by the NRC in other recently approved ITS conversionc. The difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the - r;ference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentation preference, is consistent with other reference presentations in NUREG-1433, end has no impact on safety. Therefore, NPPD does not consider a revision necessary. i 4 Bases STS B3.6.4.2 Bases - APPUCABluTY Provide additional 1 ITS B3.6.4.2 Bases - APPUCABluTY discussion and justification for this The last sentence in STS B3.6.4.2 Bases - APPLICABluTY states deletion based on the following: " Moving irradiated fuel assemblies in the Isecondary] current licensing containment may also occur in MODES 1,2, and 3.* ITS B3.6.4.2 Bases - basis, system ~ j APPUCABluTY deletes this sentence and justifies the deletion on the basis design, or of a plant specific r..menclature, etc. This is a just an inadequate operational justification, since the statement is a true statement. constraints. i NPPD Response: NPPD will provide additional plant-specific justification in the JFD for the deletion. t

g-L O Cooper SImeteer Steelon improved TS Rsview Comments

somepomi ITS 3.8.4.2, Secondary Conselnment leelselon Valwee ISC8vsl '

4 iR 3-8MY ?DOCE EJFD - I CHA10GElDIFFERENCE m COWWWIGET ISTATUS' l ~ 13 2 5 Bases > STS B3.6.4.2 Bases - RA B.1 Delete the change. 4 ITS B3.6.4.2 Bases - RA B.1 i l }

c i

The last sentence of STS B3.6.4.2 Bases - RA B.1 states: "This clarifies

i that only. Condition A is entered if one SCIV is inoperable in each of two.

j penetrations." ITS B3.6.4.2 Bases -RA B.1 modifies the end of the - sentence as follows: ...if only one SCIV is inoperable in multiple

j i

penetrations." The' change is justified on the basis of enhanced editorial ' ] clarity. The staff concludes that the change does not clarify the sentence.. NPPD Response: As there are more than two penetrations with two SCIVs in them at CNS, NPPD will revise JFD 4 to also indicate this isi pt:nt-specific design. q 6 Bases STS B3.6.4.2 Bases - SR 3.6.4.2.2 Retain the STS ~ j 4 iTS B3.6.4.2 Bases - SR 3.6.4.2.2 wording or provide j. plant specific j The last sentence of STS B3.6.4.2 Bases - Sri 3.6.4.2.2 states: "The wording speofymg j [ isolation time and frequency of this SR are in accordance with the Inservice the location of the 1 [ Testing Program..." ITS B3.6.4.2 Bases - ER 3.6.4.2.2 deletes the words SCIVs isolation ' l- " isolation time and" using the justification of editorial clarity / consistency.. times. Provide i The deletion is unacceptable. The wordkm of the sentence assumes that additional ] the isolation times for the SCIVs aie specihed in the IST program. discussion and. ., i Therefore, the words must stay. justification as. l l. appropnate.. l t l .NPPD Response: Since the CNS IST Program does include the isolation times of the automatic SCIVs, NPPD will revise the subject Bases st:tement to return to the words " isolation time and... are...." I l I i I l^ l. 'I 4 -4 4- ,m.. .. ~ ..m~ -... m

7 I . a ;. f,% - Nebraska Public Power District Cooper Nuclear Station STUDENT-TEXT Lesson Title / Number: standby Gas Treatment 'ORo02-28 02 -o Comnuter ID Number: C1280209.s-Revision Nginbg: 9 Lesson Plans Associated -y with this Student Text: COR002 28 02 (parent) COR002 28 01 _2,._ 1 a -^

a O Page 2 of 25-Lesson Number:. conoo2-28 Revision: 09 V., w/

4-

'~* LIST OF EFFECTIVE PAGE5 PAGE Bl! VISION 1 26 9 Figure 1 4 Figure 2 5 Figure 3 4 Figure 4 4 i Figure 5 4 t ]

Page 3 of 2b Lesson Number: conoor-28-02 Renision: 09 P', / Referencent 1 inhrucal Speaficatnins a Sectum 3 711, SGl' Swtem b Section 3 7 C, Scutadar) Contamment c Section 310 !!, SGT Splem 2 USAR a Volume 11. Secton V, Subwetion 314 b Volume 111 Sectum Vll, Subsection i7 1 Drau mps a llR2020, Reactor fluildmp lih V b= IIR2022, Fritt.ary Contamment Coihng and N, Inenmp e llR2017 Standby Gas 1reatment and Off Gas I alteri d llH1006, Auuharv One I.me lhapram e llR3010 Vital One 1.mc lhapram f. IIR3030, Control lilement.,ry thagtam p 1110031, Controlliiernentary thagtarn h 1110016, Control filementary Diaptam i llRiolk, Control lilementary thagram j 1110019, Control lilementary Ihagtam ' N L 1110065, Cimirolliiernentary thagtam i IIR1405, Controf lilementan lhapr im m Gl:7911!271,llPCI n Gl?7911:256 Reacios Protecunn Sutem o Gl!7911i266, Pnmary Contaminent lvilanon Notem p Gli79111267, Priven Radiation Monuionny Sptem 4 lechnical/ Vendor Manuals CNS Number 021H, Standt$ tias and DIT G% l'ihe, '1mts 5 Procedures NOP 2 2 47,llVAC Reactor llmldmp a b SOP 2 2 60 Prunan Contamment Coohnp and N,tropen iner~,p %Nm e SOP 2 2 71, Mil hatem d M )P 2 2 Ild, SUI' Y,ilW Chetkh%l 6 Otheis Niil)O 900M9. I ITect of Ret 90 sing PC. AD R 1C and Mil' CV ItiCV on PC and Mi1 Mwtenn

i + l Pegs-4 of 2h l I-Numben conoca-28 Revidons. op -l pfAfl0M OPERATOR TNtMINAL OBECTIVIYS) -) s the operstar'will dennanstrale en understanding d the Standby Oas Treatment (80T) sptem's normal and abnormal i apstaden. loads. interlooks and meerstod plant functions. 1his terminal objective w ill also be evaluated during 9 casupletsoa dthe appbcable Qualifkatim Card (n) i Si A110N OPEIMIDRENA131. LNG OIUECTlVliS 1, State the pu' Tune of the Standby Ons Treatment sptem j l 2 State the purpac of the folkm mg major components of the Standby Onn licatment aptem. a Moisture separator 6 Rough prefilter c Electne air heating element j d' liigh efficiency mlet Glier (IIEPA) -{ e Activated carbon ioJme adsor twr (charcoal filter) i f Iligh cliiciency Onal 61ter

g Fan T

3 State the kication of the major system components of the Standby Oan t reatment

l l

- 4 - Given a simphfied diagram, conectly label all major aptern components i 5. Unmg the Standby Oas 1 roatment sptem P & llTs demonstrate the abihty to phs nically trace the statems - .i dowpaths

6

- 1)emonstrate the abihty to kwate, in the plant, all hical mdicati: ins awociated with the Standhs Gas t reatment plcm

l n

1 State how the followmg sptemt mienelate with the operation of the Standhv Gas i reatment *ptem a Containment isolation Control splem I h liiph Pressure C iolant injection aptem c Plant Air uptem d MCC K e MCC.S l f-Reactor lluildmp Ventilation [ Component locations and the krauon of hical mdications/alanm may not he stated m thn test Ihe abihts of the irkhvidual to trace spiem doupaths and state hwanoas is indd %lwilie mstaneen mas he cosered m the i lecture, plant tours and'or OJ l - i { a l .w... ... ~.,,, ,y,.

i I Pagt $ of 25 l IAssosi Ninselwer con 002-28.or Revision: 09 i e Oi f ICRWefm OPFRATOlt WRMINAL ORJECTIVF1&}: i %s operska will hulreta an undwWandmg of the Standby Oas Treatment (SOT) systern's normal and abnormal cperatism, design features, and interlocks, meluding analysis of and responac to system casushics. - This will be j damnestrated by succoneful completion of scheduled wntten exams and simulator demonstrations, as applicahic, t i i LICENSED OPI:RATOR ENAlli.ING Ol3flIllVI.S 1. Idcr.tify the Function (n) of the Standby Oas 1reatment (S01) sptem 2(C) Given condition (s) and/or parameters asweisted with the Standby Oas Treatment syntent, recogni/c and indicate thow conditions w hich would be an entry condition into a lechrucal specification 1.imitmg "ondition for operatum actmn at:tement and/oc which eseced a safet) hmit 73 (C). Given a specine Technical Speenfication Lumting condition for opetation or safett I.imit annetated with the Standby Uns 1 reatment st* tem. identify the appheable basis for that I.imiung Condiuon or Safety I.imit - l 4 0 ven a condition of the Standby Oas Treatment aptem. idenufy any alann th 4 4hould actuate. i i klentify the relationships (phpical and/or cause elrect) that cust between SOT and the system / components l below. l Ikactor fluildmg Venidation aptem .{ a b Primary Containnient c. Secondary Contamment u r-d llPCI e IIRP/Otrann f Process Radiation Momtoring sptem n 6-PCIS i h Plant Air estem r 6 (C) Indicate the electrical pmer supply to the followmg a Sptem valvca i b Sptem fans and heaters c initianon logie

7(C)

Onen a specine low or malfunction of the Standby Oas Ticamient n stem. analv/e the mtuation and in,heate the etTect that the loss or malfunction uould has e on Secondan Contamment diffeiential pressure -t b OIT wite releaw rate e_ i'riman Contairmient pressuie f d Secondati Contattimetit !adiaOon/cofilamillJtiot) le\\ Cls Giveri plint and/or Standb Oas Treatment system cotiditions app l} the design thatures and/or interloels that. M (C).. 3 . provide for the behm bsted iteme to determme the resultant condition of the o stem .-a. Anomane o <enumtiation - b, - Chat'doal hed deen) heat removal c? L hhuture temoul - -d

Radaucuve puticulate nitration 7

lbum poduci pa< removal / charcoal beJ etention. e - N. F -. j ' f I tb. >E I? I j s 3l--___-._ A -- i-' h n- ,,.6.:.a,, m, -m- -,m e ,--e ~

Page 6 of 25 LeMoti Number: conoo2-2e-02 Resislori: 09 O ' LIGilSED OPERATOR ENAll!.lNQpil!ECIIVl3 (Conunued) 9(C) Given plant and'or Standby Gas 1reatment n stem conditam, appl the belou t hsted) concepts as thev are 3 assiciated with the S'andby Gai lreatment aptem and predict the resultant conditnin of the sutem a lleat removal rnechanisms b Air opersted valves operations 10(C) Onen a specific condition below, analy/c the siiuation and indicate the ellwi that the condinon uoulJ hae on the Standby Gas 1reatment system AC ard DC power failures a h I'rocess radiation momtormp failure c RPS failure d Plant Air sptem failures e Deleted f Deleted 11(C) Unen a specific precaution or hmitation apphsable to the operation of the M rl etem, indicate the basis lot and'or appk the precaution or bruit 12 (C) Predict the consequences of the follow mp conJitnins on the SO' sutern d iligh/1.ow sptem llow b i hgh train temperature c lhph tiam moisture content d l'an trips ~ k nEI es k Nc ikes !k n i i( It cSNI ibOIfk t hiIniN

~ Page 1 of 25 imm Numbers concoa-re-02 Revision: op A l. SYST EM ilRIEF DESCRIPTION A Sptem Purpose 1.00 l.5c S0 01 1. With the Reactor fluildmp isolated, the STANDilY GAS TIEWIMlINT (SG'l') sptem uill reduce and mamtam the Reactor limlJmp at a nepaine pressure of at least 0 25 inches of w ater 2 Sui processes atmosphere from the priman and secondary contamment uhen high radiatmn lesels required a splem with a higher fihermp capabihty than normal s entilation splems provide to hmit the disharge of radionuchdes to the environs 3 Sul pertorna leak tests on the secondan wntainment to ensure semndan wntainmerit mtepnt) 11 Deupn liaus SO.07a 1 140th SOI sptem trains start automaticalh m the esent of a secondan containment isolation ugnal 2 Alier both trains base staned one tram may in placed m standby mode lhe standby train u11) restart automatically if the opeintmg unit indicates l.ow Flow" 3 lloth trams mas be controlled 1 om the mam Contiol thum 4 in the event a tram is being operuted for test purposes, a secondan contamment nolation ugnal uill automatically select and start the other tram lhe signal will also prouJe the proper ahpurnent of darnpers in both trams 5 Manual abgnment uill provide for decas heat ternos al from tission pnducts deposited on either liher bank 6 Gas temperatures, heater temper atures and over all litter bank pressme (blTetential will be indicated and high values will be annunciated in the Mam Control Room ? low ilow m the selected tram, automane transfer upon low ilow m the selected tram or low flow m llie ntJ1)dh) train aftet autormllie transfer due to failure of the selected tram uill be annunciaied m the mam Control Rooni C 1 eshnical Npecificanons 1.0 02.03 i Necuon 17 II(NG I e siem) 2 Section 3 7 C (Second.in Contamment) i Nection 310 li(NU l ostem) r_

Peg 7 8 of 2$ ~ Inson Number conoo2-28-02 Revision: 09 I sg i D Spten, Components SO.04 1he S01 sptern is comprised of tuo identies! 6hration trams, each capable of l(X66 rated now The major components of the system nic 1 Vahes 2 Moisture separator 1 Rough pre 61ter 4 lilectric air heatmp clement 5 I hgh !!mciency Inlet 61ter (also refened to as a ihph limciency Paniculate Air (IIEPA) filter) 6 Activated Carbon loJme Adwrher (also called the charcoal filter ) 7. lingh Emeiency Fmal filter (llEPA type) N Instrumentation 9 Fan i 10 Discharge piping hg2 li liasic System Operation i Durmg normal operahons, the Standh Gas 1:eatment sptem (SO l ) is aligned for standby operation Ihis splem can then be started enher manualh or automatically 2 When rtarted. the SGT can take a suction from one of four areas a kcactor iluildmg renalation dist harge plenum h Primary Contamment e illOll PRENstf Rli COOL.AN I INJI:C iloN tilPCI) I mbme Gland Seal exhauster d Su l room at: 1 The quantity of airbome contammants is reduced as the air passes through the tram This is accomphshed by both mechanical lihration m the tihers (both tough arid 1(EPA tspe) and by chemical adsorptien m the charcoal 6her (imhne bemp the predommant iwtope of concem) Ilach !!ain is eqmpped Mith an electric.11r heatillp element. Hhich rediNes the relative humids of the air prior to the charcoali.her. thus irnproung the cMeiena of the charcoal 6her s-kib' ntolis e force i is ths process is pr os ided M a single stage s ortes ts pc tan in er.ch tram 1:ither tan and 6hsr tram is capable of paning 1(x% of required llow Air is tran*1uned through lir unJes pround discharge pipmg to an eles ated t eleaw gumi (ERP) thr releaw to the atmospheie

Pnq7 9 of 25 lession Number: conoo2-28-02 Revision: 09 A. LO4*a 4 Automaue Operstion lloth trams will start on either high drwell pressure (s. 2 psig), low a eactot u ater level (> 4 4 $*), m high radiatson m the Reactor fluildmg exhaust plenurn(s 100 mr/1fr) b Both of the fans start (if selected) anJ the vahe hnc up n estabbshed winch will draw air ftom the Reuefoi fluildmp, ftom both the ventilation eshaust plenum and SOT room air l hen discharpe it to the elevated relcaw pomi The vah e from Pnmart Containment opens to ahpn it to SOT system noction S0-07f c With the system operstmg Reactor lhnlding pressure will be lowered to at least 0 25" of w ater vacuum II. SYSTEM COMPONENTS A Valves Fig 4 1. Sol I A(lli) Inlet and Disharpe vahes for Splem A(ll) a inlet. AO 249(250) b Discharpc AO 251(252) 1.0-09b 10a,d e lhe vahe3 are butterth salves These s ah es are normalh clowd. but they open ahenever the associated fan is energiud Actual s ah'e position mdication a provided by tuo hphts (preen closed, red-open) hicated nest to their control switch on Panel K The inlet anJ cischarpe s ahes will fail to their full open position (fail safc) on a loss of power or control air pressurc. m order to allow for system operation should it be required 1 oms d The powrr supply for AO 249 and AO 251 =>lenoids is CCP-1 A The power supply for AO 250 and AO.252 solenaids is CCP.lu 2 SG1 A (11)lhluuon Air sahe, AO 270(27I) The purpose of these s ahes a to proude a method of remoung decas a heat 00m the ostem aller operation 1.0 09b.10a.d b The s ahes are butterth s ahes Ihe sahes are nonnalh closed but thes opert u hen arumnatiot, signal n ieceit ed Indication of the actual iah e posinon is plotided by two bphis (preen closed sed open) located nesi to their control nuitch on Panel K On a low of nower or control air piessure, these vah es fail open (fail safe) to allow system operauon if required l he iesu wtmp onnee located upstre.un m tha hne is mstalled to hmit c llow d Ibe shetL sahe !wated turther upsacam m thn hne piesens baskil w tiom the $(il tiain to the imm i

Pego 10 of 2$ Leshon Number: conoo2-28-02 Revision: 09 ,s~ LO Ma e lhe power supply thr AO 270 soleno J is CCP l A. The power supply for AO 27i solcrmidis CCP llt hg4 3 SGT I A(lli)l: low /Rs ilidp DT Control s ahe. DPCV 546A(ll) a The purpose of the vahe n to mamtam ihe proper neraine pressure m the Itcactor lluddmg 1.0 09b b 1hc $ she is opened by spnng force anJ closed by air pressure lhe vahe is controlled frorn Panel-K 1he control suitch has three posmons, t AU10. IDP CONT, and OPl!N e When the cont ol suitch is in AU lO. with an mitiation signal present, or m OPliN, contnil air n hhded and the s ah e a full open When the controf switches are m AlflO. without an nunation signal,or m 12P CONT control air supply pressure to AD 546A(ll)is provided via an electro pneumane converter (li/P 546) Ihe conserter recenes an cicetrical cont of signal frorn Reactor ihnidu J.4GT DP Controller llV-DPIC 8.1511 The output ofIIV DPIC H1511 maintains Reactor fluilding pressure at its tape setpomt by modulating sahes AO 546A(ll) d Norma:h the vah'c control switches are m AUTO and llV-DPIC H1511 m in MANU Al, set at 100% output to fulhwlose the valves Thn pres enis the ulves from continuously eschng w hen the utstems nic not n scruce e Indication of actual sahe position n pmuJed by two hghs a pteen elosed. Ied open) located on Panel K l.0 10a.d f On a loss of power or control air pressure AO 546Alli) faik to us f ull open positions 1006 g The power supply for AG 546A(II) solenox' a CCP 1 A (111) hp5 4 SOT Inlet damper from Reactor fluildmp INhaust plenum ( AD R 10) I he purpose of thn damper n to ahpn the Reaetor ihnidmp exhaue plenum to the [ SOT sucuon ihn damper n dnabled open 5 sul vahe kneup tiom the Pnman Contamment eshaust sentilanon kne to the Reactor lladdmp eshaust senulanon plenum uuh/es dampers Al).R I A A AD R-til a AD-R I A is the 1:shaust Damper itom Pnman Contamment to the Reactor iluddmg ihhaust Plenum b AD.R.til n the SUl' Inlet Damper from puman Contamment Ihe purpose of these s ahes n to stop the 11ou of mr hom the plunan e contamtDent to the ReAlot lhillJing exhausi plenum ad tii tedneet that flou to the sucuon of the Mi f ostem M1l1 t he Reastor Itm\\hng exha.ot pienum hiph iadiation tnp mput to sul n based on a fuel handhnp accident A high aJianon conJmon cou)J aho anse trom improper s entmp of priman contamment

Pago 11 of 25 l#uoll Number conoo2-28-02 Revisiori: 09 Q l.0 09b d When the PCIS Group 6 is mitiated. both SOT r ams nuttate AD-R 1 A S0 07a shuts to secure flow to the Reactor iluildmp eshaust plenum and AD R lli opens to abgn the SGT swtem to the primary contamment eshaust ventilation hne LO 10a.d e AD R.I A will fait c'osed and AD R ill uill fail open (fail safe) on a loss of umer or control air pressure l I.O.12a f-Maumum open position for AD R-ill n bhicked to hmit trasci to 50% open This action u as required to pres ent baclJ10w into the Reactor iluildmg exhaust p:enum during operations of high flow rates from primary contamment 0 e, during de merimp to SOT through the 24* valves) LO 06a g 1he power supply for AD R l A and AD R 1) solenoids in CCP I A. hg5 6 IIPCI gland seal condenser exhaust vahe (l(PCI AO 275 ) S0-07b a The purpose of this valve is to ahpn the diwharge of the iIPCl pland seal exhaust blower to the SGT tram Non Condenuble pases collected in the llPCI gland se l exhaust condenser are then vented olithrough the littered floupath b 1 his vahe in normally closed, but it opens on mterksk when the iIPCI m pland seal exhaust blouer is energi/ed Tha valve fa ! closed on a loss of p<mer or control air pressure lig 2 7 CrosvConnect sahe (49) 3 1.0 0Mb,9a a 'Ihe purpose of this s alte is to provide coohng air flow to remose the deca) heat from the charcoal filter of the tram which has been veured after senice b I he valve n manuall) positioned to maintain a 11ou rate of - 240 cfm (acceptable ange 1No to 280 efm) When one of the two lilier trams a secured, the operatmg tram drau s a small amount of air ihrough the toom au valve of the secured train. through the cross connect s ahe and a routed to the suction of the operatmp fan in ilns was, decas heat n removed f rom the secuied tram 1.0 6Ke e I)oring a 1)llA 11)CA with coticun ent low of otTsite powei,ind sitiple failure of AC power, an operated solenoiJ \\ ahes will fail open A mechamcal stop hmits the manual openmp of the vahe to hnut the llou that can b> pass the operating tiaisi l'ig 2 M Sul I A(lll)ltypass sahe l AO 255/256) 1 0 09h.II 'Ihese s ahes are normalh hicLeJ close. and hase no automatie openmp a feature, to elbure proper opeiallon of NU l ss stem lhet are operated hs two-posilloti Leyhwk suashes hicated on Panel R m the Control Room 1 he t)pl.N positiori oti thew suiiches a uvJ iinh tor suts einance lesting } O Ida d b $ he tihet tr.im bs paw s ah es u ill lail clowd ifait safe) on a low of power or wntrol au prewme

j Pag? 12 of 25 l Lemon Number: conoo2-28-02 Revision: 09 1 O

y LOMA c.

The pourr supply for AO 255(256) nolenoid is CCP.I A (18) Nu1E 1he followmp m components con <titute a lil:er tram (ligure.1) the reader in renunded that the Iwo parallel trains are identical and toch is capable of passmg 100% flow l1g ) Il Moisture Separator 1. Purpse 1.04Mc The moisture separator remmes entrained water dioplets and mnt from the SO42a airstream to prevent pluppmp of the inph etlicienes tilter 2 The separator is constructed of woven mlon me h which traps the u ater droplets 3 The removed w aier droplets dr ain to the Reactor iluildmg equipment drain sutem via a 'U" trap The 'U* trop (sunitar to that Ibund m a household sink dram) penmts continuous diamage but prevents contammated air from entermp the diam system or outside an from entermp the filtratton tram lig 3 C. Rough Prelitter i Purpose 1.0-OKd S0 02b l he rough prelitter removes lar ge particulate matter llom the airstream. thus muumving the pluppmp of the hiph etlicienes lilier 2 1he pressure drop across the rough prefilter acts upon ditTerential prewme switch I)PIS 531 A(ll) At 0 l" water D/P. an alarm (*SG1 Allll PRiil ll.Tl!R 111G11 D/l") annunciates on Contml Room Panel K, mdicanny that the prelitter needs replacing 3 ~lemperature indicator il 532 AIll) provides Conuol Room indication of Prelitter 1 A(lil) outlet temperature on Panel M lip 3 D lilectrie Air Ileannp l.lement i Purgme I.O 0xe SO 02c 1he electric air heater rahes the temperatuce of the air stream to reduce the relatae hunuditt The relative hurmdity will change from 100% to tipproumatch 70%,if the air is drawn from a steam environment NtHti Relatne humidm is delined as the amount of monture m air as compared to the amount that the au mulJ contain at that temperatme and piewure Retam e humidm is espre sed as a percentage v Ig k s h i bs a tine 2 N N N'hefiter

Page 13 of 25 Lemon Ntimber: cor< 002-2 8- 02 RcVhlon: 09 A ~~ b One 5 0 KW heater 3 When airihm thiough the tram in alune 800 Cl-M ttaj outlet temperature is below 170*12, heater operanon a contsolled using a 5 pospion switch on Panel K Switch positions ure a OFil. gumer n weured to both heaters b 1,0W 1xmer a supphed to the 2 M KW onh-c MiiDIUM pimer is supphed to the 5 0 KW only d lilGli ptmer n supphed to both heaters e SPARli not used 4 'Ihe moisture content of the air leavmp the heater a mJiented liy Mi Sil A(ll) on Control Room Panel K 1.0 12b 5. Ileater inps a j hph air temperature if airstream temperature reaches 170'll at the outlet of the heater, the heater control circuit sull trip The heater control cireus wlli automatically f esel at 16011 ?% b lilectneal merload Ari overeunent conJiuon tops the supph breaker to that heating element. c l.ow airflow if airthm through the u am Jrops to less than K00 clm the heaict control ciremt willinp 1.0-06h 6 Power supphes SO.07d,c a Sptem A heateis are pimered from MCC-K and Spiem 11 heaters aie powered fiom MCC-S h ior each tialn. there are two feedet hicakers on its respeeln e MCC ()ne breaker supphes the 2 M KW heater ufule the other supphes the $ o KW heater lleater control power is 120V AC and n supphed from MCC Ktsi e lig i li lhph luliciene) inlet hher l A 1(lll l) 1.0-OxJ S0-02d I. Purpose 'Ihe high etlicienes mlet tiher remmes airiume particulates uhich are larger than 0.T0 nucions from the airstream 2 Ihe prewure diop ailow the tiher acts uiwin ditiereutt d prewure su uth !)pis - i 514 Atti) At 2 o' v.ner D11 an alaim 601 A;)l!lil PA fil/il'R \\11111iilhill D19 annuncia!es on Conoo! Room Panel K mdie emg that the tiher need, v leplailnp I~ lhe elllelenes of the tillers n tested b\\ using J: oe" 'phthalate tD()PJ smoke 1

l 1 Pago 14 of 25 Lesson Nuniber: conoo2-28-02 Revision: 09 O \\ Fig 3 F Activated Carbon lahne Adwnber l Purpose 4 1.04)Ke S0 02c Ihe adsorber element remoses 99% of the nhoe m the air stream liir mlet conditions in which the mfluent has a relatne hu.tuJm ofless than 70% 2 INcessive rnoisture or orgaruc materials (such as tubncar ts) will reduce the iodme adsorption capabihty of the charcoal filter if these are not previously removed by the demister, heater or filter Wet charcoal can also cause a smoldering fire in the charcoal bed as the moisture releases heat when drying. 1,0 12c 1 Alarms a If the relata e humidity of the airstream enresing the charcoal tiher rises to 70%, an alarm (SOT A01)lilGli MOIS l11Rii) annunciates on Control Rann Panel K, indicating escessive influent monture b The pressure drop across the charcoal litter acts upon dillerential pressure switch DPIS 5%A(il) At 2 0" u ater D1'. an alarm (SGT Alll) CARilON ADSORP llON Fil.TliR ll1011 D.1') annunciates on conttol Rmm Panel K indicating the need to replace the charcoal filter 4 Indications a Moisture mdicator Ml 535A(II) prouJes mJication of the austream monture content entermp the adsorber element on Control Rmm Panet K b 'lemperature mJicator ll 317A(!!) piouJes Control Room indication of adsorber element outlet temperature on Connel Rmm Panel K 5 1:ach tram a equipped with sprmkler n<wles from the fire protec. tion system in the unhkely event of a fire. TSicte is also pipmp uscJ for tesung the ellicienes of the charcoal filter Freon is mjected upstream of the adsuber element and a sample is drawn downstream of the fan The quanuts of freon removed mdicates how eticcin ct) the adsor her element is performing iig 3 G lhph lillicienes I mall'ilter l A 2(ill 2) 1 Purpose 1.0 OxJ S0-02f The high etlicienes final tilter remoses both cuhon Just and particulate which mas be carried from the charcoal tiller ihe t'heimg els nent a identical to thai of the mlet tiher 2 The pressuie drop across the tihet acts upon ditretennal pressure suitch Dph. 53N At11) At 2 o' uater D<1'. an alarm (%G I Allll 1IILPA i 11,~11 R A2lll2l 1llGII D1') annunciates on Control Room Panel K nheaung that the tiher veeJ4 replaiing iI AJJitional Instrumentation w 1.0-01 12 b i 1he temperature of the airstream leaunp the tram o sensed bs tempet ature su thh IS 539Atil) At 2t N) 11 an alann 6G l Atib ol'Il l.1 lilGil ll'MplRA ll'REi annunciates on Control Room Panel K

4 Paga 15 of 25 Lesson Number: conooz-28-02 Revision: 09 f~~ >. NQ1E This condition may be attnbutable to malfunctionmg heaters, decay heat fronti limon products or combusuon of the chascoal Operator action is required to de'enmne and concet the cauw of the high temperature 2 Two instruments are provided which nense the pressure drop across the entire filter tram a When ditierential pressure susich DPIS 541A(ll) senses lo 0* w ater D<1' across the tram, an alarm (SG1 Alll) 111011 D/P) annunciates on Control 1(oom Panel X,inJacatmg a malfuncuan of the fan vones control b Dillerenhal pressure cont oller DPIC 541 utilves the pressure drop across the tram to generate a conirof mr signal u hich is supphed to fan sones control Thus, the fan sortes is automancally adjusted to tan system flow raic Figi i Irans LO 12d S0 02g i Purpose. T he fans provide the motive force liir flow through the system 2 1 hey are hicated dou nsticam of the process filter i his helps to minimve the contaminauon level of the fan, thereby facihtatiap maintenance 3 The fan is controlled usmg a 4-position switch on l'anel K. Indication of fan status ~s is also provided on l'anel K by two hghts (green-otT, it l on) a OFF power is secured to the fan h STANDllY the standby fan starts uhen flow m the operatmg te am drops below 800 CI'M if I) the fan control switch for the operating tram is in RUN OR 2) an auto imttation signal is present AITI O the fan remams oil unless an inniahon signal is receased e d RUN pimer is supphed to the fan 4 Ratings a lhe fans rated tion is 17S0 Cl M b ihe fan motor is a 460V AC unit uhich is rated at 15 lip I,0 06h S0 07d.c 5 Power for fan IE in fdter tisin I is supplied from MCC-K and power for fan IF in litter train 2 is supphed fnmt MCC S. 6 1:ach fan is equipped w nh a Run 1ime integrator w bich is uws! to momtor the run ame for the fan (l?F R ll:11 R lFT I his miept ator is energved w henes er the N01 fan bicaker w clowd lhe Ian is eqtiipped u tlh an Jif-opelJied s allable s olles Nhtem flow wtpolul is .lJiustable usmg ditTerential precure controller DPIC 541 hicated on Panel K (see il1121

. - - _ - -. _ _. _. ~. _ _ _ _ 4. ) + j Pags 16 of 25 l Lesson Nunsers conoo2-2e.o2: Revision: ot m) - F!g 2 J. Discharse Piping j l. Purpose. The disenarge piping provides a shielded (underground) llowpath for transporting proccu ellluent Imm the fan dncharpe to the elevated release point l i =1,0 12s 2-To al system nowrate is provided by a now mdicator (F1 $43)locsted on the l common discharge piping. This Cow indicator also supplies an input to a dual. alarm unit (high and low dow) When system dow is measured to be 1958 CFM i f and rising, a high alarm will annunciate on Panel K A high alarm indicates a problem in the system The high now could be a leak m the discharpe of the fan, a - large gap m the filter tram, or a controller that is wide open and not controllmp D/P. - A low dow alarm is actuated aller a 15 second time delay w hen system Dow n l 1200 CFM and hmermg if at least one of the follow mg conditions also cust teactor low w ster level, high drw c!! pressure, or high radiation in Reactor lluilding ventilation A low now may cause the buildup of airborne contammation ? m the area (s) bemg edausted or the mabihty of the *ptern to mamtam the required D/P. r 3-An cacensively high water level in Z sump at the base of the the ERP can cause a low syslam flow that will nul r. lear by shiAing fans This would occur if water backed up into the underground piping creating a smaller opming and thus a larger .l back pressure on fan dischersc. The annunciatora and the sump pumps should control lewl to prevent this problem; l 4 The temperature of the airstream is indicated on Control Room Panel R hv + temperature indicator 11547. 111. INSTRUMFNTATION ANil CONTRot.S i A Instrumentation l. Control Room instrumentation i instrumembeatmn - Sen9nc 19mF13re I)ewrmtion a - Pre 6her i A(Ill) 0udet Temperature I'li 512 Atil) Momtors the air temperature before the TI 512Atll). 50100*lt. Panel K eteetne he ners b lleater l A(lli) Outlet Moisture Ml!531A(ll) Monitor 4 the moisture content of the air Mi $33A(ll),207150*F dewpomt, leatmp the heaters PanetK i . SGT A(II)lii litt Fiber Outlet. MlI515A(ll) Monitors the moisture content of the air e Moisture. Ml $35A(lit 20".l$0'F entermp the charcoal filter. i dewpomt. Panel K d. Carbon litter Outlet Temperature i 11517A(ll). 50Mfo T Panel K - .Tl:517Atil) Monnon the a:t temperature leaung the - t 6her tram and entermg the fan r Stil Discharpe Ileader iemperatuie, . lli54' Monnois the air temperamte leaung the D

11 W30 MrM T Panel K fan and entenne the thscharee rumnv i

4 .' I .-_c, .-. s ..m.. n~

e Pcgs 17 of 2$ Lesson Numbert conoor-2s-02 Revision: op C-l Ins'twentlocatiop sensint Pomt/fvpe _ pesenpoon f-SOT Discharge licadcr I: low FE 545 Monitois total system flow supphes F1545,040 (X 100) Sci M, flow plot PMIS PI N29I PanelK g Reactor fluildmg/ Atmos dPI N15A(ll)(C)(D) Morutor s the average Reactor fluildmg D/P Recorder,llV DPR H15 to atmosphere dP 0 5 to +0 5* 11,0, Panel R h EF R lE Run Time Integrstor SOT MOT-(!!F R lH) Monitors the run time for SOT Fan ll SGT 1RM HFRli,0 99999 9 hours, Panel K i 1.F R IF Run Time Integrstor SO'l Mol-(EF R lF) Momtors the run time for SGT Fan IF SOT TMR lil'RF,0 99999 9 hours, PanelK 2 lecal Instrumentation Instrument /Hange 1yeation AdJitjonal functtons a SOT tmit A(II) differential pressure SOT room Proudes alarm m Control thwim at 10 mdicator, DPIS 541 A(ll). 0 20* 11,0 mches of unter dP h Prefilter i A(lll) ddTerential pressure SOT rann Provides slann in Control Room at 0 4 mdicator. DPlS 511 A(ll). 01* ll,0 inches of u nter dP c Prefilter I A(lli) outlet temperature SOT nsun

ndicaior, TI 2666Afil). 0 250*F d

ihgh Ellicicney litter i A l(lli 1) sol rmm Provides alarm m Control Room at 2 0 difierential pressure mdicator mches of water dP Dl'IS 514 A(lit 01* 11,0 e Unit I A(Ill) moisture mdicator Sul anun befine charcoal filter, Mi 2661 A(II), 0 100 % f Umt i A(lli) Carlen lodme Ad+ni cr SGT :mm Proudes alarm m Control Room at 2 0 ditierential pres =ure mJicator inches of u ater dP DPIS $36A(lit 01* 11.0 p Unit 1 A(li1) Carbon lahne Ads.nbei SO 1 :oom outlet temocrature mJicator ll 2667A(ll) 0 250'F h Iliph litlicietiey litter i A 2(lll 2) SUT tmm l'roudes alann in Control Rmm at 2 0 ditTerential preoure m,hcator inches of u ater dP DPIS-SIN A(lll 0-1" l10 i-Moisture Separator i At !!!) NG 1 room Proudes local indicauon of pressuie dalferential jiie%sure md4LabV dlop.iclow the moisture sep.it.thir DPl4 $10A(llt (' 1" ll.() i v ll.\\larTut lilleilocks and lops 1.0-t ti,12a J I Alanm

e P a. g 7 10 of 2$ Lemon Number: conoor-28 02 Revision 09 O. Itir4muen irtinagns DevgelScumtnt Addi!!ondfurtens [ a SOT A(B)PREFil.Tl;R DP!S 5)l A(11)0 4 mches of water 1.ocal mdication I11011 DS', K 1411 (K 2/Il 1) b SGT A(ll) LOW l1,0W, FS.540A(II) 400 dm I) Secures power to electne air K. I /l%2 (K.2/D.2) heannp riements m that system 2) Sends a start signal to the other fan if it is in standt9 c SGT A(ll)llEPA l!!.TI;R DPIS 534 A(IO 2 0 inches of u nter laal indiention A1(111) filGil D1', K. I412 (K.2412) d SGT A(ll)OllTILT TS.519Atil)200 I 1110111EMP. K.1/A.I (K.2/A l) e SGT A(D)IIEPA Fil.TER DPlS 53NA(ll) 2 0 inthen of water 1.ocal maication A2(112)111011 D1', K.I/C 2 (K.2/C.2) f SOT A(ll)lflGilMOISTURII. MA.535Atil) 7(W. relative K.I/A 2 (K 2/A.2) humidity g SGT A(ll)CARil0N DPIS.5 %A(il) 2 0 inches of w ater ADSORPTION Fil 'll!R, 11! D15, K.I/C.I (K 7/C 1) h Su r A(ll)lilGli D1', DPIS 543 Alli) 10 mches of unter K.labi (K 2/lbt) i SGT UNIT 11101111.OW. Fl.5451958 cfm nsmg K.2/A.3 ) SGT UNil 1.OW Il.OW. Fl.5451200 cfm louenng (aller a K 2/ll 3 15 see time dela)) When an auto initiation sienal. present L Hl:AClOR lll.DU lilGli LIV.DPIC.815 low. I 5*WG after a PRI:SSURii, R 2/A 4 45 see I D i RI:ACIOR 111.D0 LOW llV DPIC.x15 Trips nhaust fans wiected to AU FO PRIISSURH. R 2/ll-4 1 ou 15*WO after 45 see 'l D 1,0-ONa,10b Interkvka and 'l nps 4 a lilectne air heatmp elemen;

S 540Atllt ii i nps the awietated beater Khodm 21

% ends a si nt siprial to the other fan d n is in standin b I!h'Ctric ail Ilealitig clerlietil l S.540 Allli& 54 i Ai }} } l t ips g})e aw tel.lled he. iter Autti!11alicalh (air ternperature out of heatet ) !?O i reset at 160 F hich temperaiute

Page 19 of 25 leuon Number: conoo2-re-02 Reihlon: os q InterlocWhips initiannt I) cute /Setigunt function c. Reactor llutiding venulatmn Senun s 1) Startduth SOT fans, winch causes the edaust plenurn radiation 17 4 30A,ll.C. and 1) I np awietated mlet and outlet s alves to nainstor trip Uruts open 17452 A.ll.C. and I) l b.l h ( 100 mrdir or dounwele 01 2) Room an supply s alves open rutan. Male suitth not in OPl:RAlli 1) l)1' controf s alves open 4) Mii miel s alte from the primary contanunent sent hne opens 5) 12.shaust s alte from the pomary contamtnent to the Reactor fluildmr exhaust piellurn shuts 6) Imuntes a secc7dary containment 1%olabori Mllli i out of 2 taken Iwice logi is used for both the Ih lh radianon and nude Switch not m operate trips All 4 inp unit

Jownwale are reymred to perform the same functions as the lh lh trip s

. ~, d I bgh lityw ell Prewire 5 12 A, it, C,1) from RPS Response n idenocal to Reactor limidmp through the PCIN 2 0 psir senulanon exhaust plenum radiauon momtor J tnp OR l.ow Reactor Water level 2 3 lul A.ll.C,1)(switch #1) from tcactor protechon e stem through the pranarY contamment swlation ssstem > + 4 5 inches C Controls in.09h. l oa d i Control Room Conuols item /lganon synch Po_sinon3 }:unenons a M1'l i AU11) thlution An. 3 positions, Cl Osl: At HO, Cl 0%I:.Vah e iemains clowd. posinon SO T-AO.270 (271 L Panet K OPl:N n inJieated hs preen lamp l At rlo Vahe remams closed unul an imttauon signal h reecned ()plN-Vah e i> pens {hNllon h ind T ' llc.) la t ed 1.imri s/ i l

Page 20 of 25 Leuon Number: conoo2-re-o2 Revision: 09 .O I / l Sunch bmuons Euncoom ltrmination b SOT l A(lli) inlet 3 gxmtions, CUhl:, AU lo, Cl.Osl: Valve remains closed. poution SGT AO 249(250), Panel K OPEN is mdicated by preen lamp AU i 0 Vah e remams closed. opens on mierlak w hen associated fan n enerp:/ed OPlit.Vahe opens, position in mJicated N red lamp e SOT I A(llh Dncharpe 3-rumtioni. Cl,Osti, M J IO, Operatnin n identir,al to AO 2% 250, SG1 AO 251 (252), Panc.' K OPEN ahose d SOT I AIIll)llypass 2 positions,(Leykwk)Cl OSE, Cl.OsE.V.ilte is closed and Lc) locked, SOT. AO.255 (256), Panel K OPl?N position a mdicated by green lamp OPEN. Ihn position n umi for j sun cillance testmg e Sul I A(lli)lahaust l'en 4 ;wmtions. Ol l' S l'ANDHY. OIT. fan remams olf lil:.R.lh (IT R il ). Panet K AUTO, RUN ST ANDilY I an ternams otr anJ

tarts if flow m the op;xmte train drops below S00 cim and.in inihation signal is present. OR the op[xmte fans control suitch n m RUN and its llou n 400 clm AUl O Inormal positum)- i he fan remains oil unless an initianon sipnal (drvuell [vessure et reactor w ater les el lou er Neacior Huildmg esh.not plenum lugh radianon) n received RUN I an n energi/ed f

SGT I At 111)lleater Control 5-;xmuont 01 l 1.OW. 01 l Ileaters remain otr SGI-illR SGilA (S01111). MEDIUM,Illull SPARli Panel K t ee Note) 1.OW.Pouct a supphed to the 2 x KW S heateronh MI'Dll %l'ouer n supphed to the 4 o KW heater onh iIlGRPouer a supphed to hoth heatet, sP \\ki-n.u usd

Pago 21 of 25 lest.on Number: copoo2-se-o2 Revisioni os O l'rrn/lgxstion $9:id1%itsons func1: ens h0E ror ar>y switch poutions irnolving gwmet to the heatern, txith of the following conditions must be met air Dow through the tram must be greater than 800 CM and outlet temperature rnuxt not esceed 170 T If not, the heater s will remain de energized g Rx ilidp/ SOT D/P controller, 2 positmns, AtllO, MANIJAL AtJ10 Proudcs control signals to IIV 1)PIC.H3511, Panelit valves DPCV546A and 5461) to automatically control Reactor Build.ng i pressure u hen SOT is operating (normalh set at 0 25* uater dP) MAN!!Al. Provides the operator with manual controf h SOT l A(lli)l-lou /ih Illdg 3 poutmns,lul' CONI, Alllo, OPl!N Vd' e opern. position is D/P Control OPF.N mdicatcJ In ied lamp SOT DPCV 546A (54611) At fl O.Vah e position in controlled hv IIV DPlO N1511 l)pon miuation, control air is imlated, and the s ah e f.uk to its full open position e, li/P CON I Valve is controlled bs !IV. DPIC N1511 T he vahe controls m response to urnal from llV DPIC N1511 even if a Group 6 imlation urnal eusis NDE Reactor fluilding pressure of1 O 3N" u g causes SGT DPCV 546A(ll) to fail open When m AlJ l O, s ahes fail open on receipt of a Group 6 isolation ugnal Vahe will remam open, unable to be contralled until the signal is reset i linit I Allli)di!Terential 2-posinons, Atrio, MANt!Al. Alll o prouJes control signal to fan preuure controller DPlC-541A wrtes damper which automaticallt (54111L Panel Vild.K controk ditierential pressure aerow the liher unit t Nonnally set at 10 0" u ater A19 MANt: Al. proudes opeiator uith manual control t Damper AD R l A A AD R-2 poution,lh iluilding,50'l RX Huildmp -(AD R l Ai recenes, 111, Panel K open signal ( AD R-1II) recen es close ugnal 'M il - dD-R I Ai recenes close signal t ADL & tecco es open sicnal St.ML On Pris (iroup 6. or lou of wmer or air damper AD.R 1 A clows and AD-R 1it opens

eardless of suitch pounon t

Pnq7 22 of 2$ Lesson Numbers conoo2-2e-02 Reilsion: 09 mC: IV. OPI' RATIONAL SUMM A RY A Normal Ststus (standby) Durmg nonnat oleration, the fans and heaters will be oll uith their control switches in AUT 0 and 111011 positions, respecovel) All sol s3 stem ahes controlicJ from Panel K wdl be closed and all their control suit <, hen ud! be in AUlo. except for the Tram Ilvpass valves A0 255(256)which are m CLOSl* Rs lilJp'501 DP Connoller,IW DPlf N.1511, i wdl be in MANUAL with the act at IW4. to prei ent the s ah ca from eschne avhen the systerns are not in f.emcc 1he SOT Inlet from the Priman Contamment valve AD ib 111. uill be open and the Poman Contamment to Heactor iluddmp lhhaust Plenum vahe. AD R.I A. wdl be closed The cominon controf suitch Ihr the tuo s shes will be m the sul p% tion 1he SOi m!ct itom the Reactor limidmp Ihhaust Plenum va!ve. AD R 1C is dnabled open 11 Automatic initiation 1,0 05p.Ma 1 The NOT sptem can be automatically started on ci,r.er a high dryuell pressuie (. 2 psig) or low reactor unter lesel(> 54 5 mches) mination signal or high radiation m the eshaust plenum imtianon ( 100 mr/hr) 50-07s,7f 1his signal is cauwd by a Group 6 contamment iwnahon sip.nal lloth $01 fans wdl start and their respectne inlet, outlet, and Jilution air suppl) valven will open The Group 6 isolation isolates the Reactor liuddmp by dosmF th4 MOset ventdation valves. trippmp the Reactor fluildmp suppir 'md eshaust fans and by isolatmg the normal ventdation lhe 50 l'suchon from the Reactor limidmp eshaust plenum and SUT room air valveu drnu air kom the Reactor lluddmg. through the two parallel fdter trams to the f ns. and subscharged throuph the differential preuure control vah es to the eles aird release pomt The differential piessme control vah es fully open to estabbsh and mamtam Reactor lluddmg pressure at a mmimum of 0 25" u aier vacuurn The filter tram heaters mamtam the airstream telatne humidit3 below 70% The fan vortes conuol miem hnuts airstream dou thiough each fiber tram w that total prewure diop acron the tram remains less than 10' of u atei dp Nolli 'I he ddTerenual preware control s ah es hul open on receipt of a Group n isolanon signal If m AUTO. the sahes uilliemam open unable to be controlled unnl the signal n reset if vahes AD R 1 A and AD-R ill are abpned to senulate the priman contammeni through the Reactor liudJmp sentdauon etern. i e u nh AD R 1 A open and AD. R. I11 closed two additional actions will occur conemtenth 1.0 07d a AD R 1 A will close to stop the potenual spread of contamir, anon inim Priman Contamment mio the Reactor iludJmp 1 0 07b b AD.R. HI u di open to Jirect the contannnaied atmospheie bom withm prunan Contamment to the M F1 fdter trams to reduce the letel of airborne sontamlriahon IcleaWd to the emilinth to louer od siic release r ales he =*

Pag) 23 of 25 Lesson Numbers conoo2-28-02 Revision: os C. Operstor actions upon automatic mitiatmn The operstor will verify the S01 trams have prope:1 started with their vahes respondmg 3 conectly and their heaters energi/cd The operator sult then senfy the Reactor fluildmg llVAC fans have stopped and vahes have isolated concell3 if Reactor limidmg pressure a bemg mamtamed s -0 25" Water paupe as mdicated on temrder DpR 8351)(panel R), the operator sull place the control suitch to RUN for the preferred SOT exhaus fan 1he other SOT tram will be p!xed m standby by placmg its edaust fan control suitch to OIT and then to the STANDllY posmon anJ by senfymp the fan stops and Sll vahrs posinon concelly This proudes an automatic startup of the standby fan should the nmnmg SOT tram's flow drop below K00 efm 1.0-09a,1 i '.Vhen SGT system is no lonrer required to operate. 'ihe temperature out of Cse carbon filter is checked pnor to placing the runmng tram back to titandby. If the carbon filter outlet temperature of the tram, usmg T! 537 A[lI). is a 200T. then Jeeny heat removal is requirai lhe other SOT tram is stoned, the runmng SOT tram is turned olT, and its Dilution Air valve is opened This cauws room air lo be Jrawn through the iram bemp cooled via the manual cious connect vahe and out the second SOT fan Thn nenon must be performed pnor to retunung the SUT system to standby status D Manual Operation LO 07c l or those condmons in w hich the SOT q stem u ill be opes ated manually (i e, lipcl gs surml'ance, containtnent venting, ete ), the operator n directed by pnicedure to estahhsh the appropriate valve Imeup. ernure c.peratmp requirements are met and perfonn the desired emlution The actions taken will be dictated predonnnantly bt the type ofoperatmn bemp perliarmed livolunons that add energ3 to the pnman contamment require manual SGT n stern operation to prevent pomary contemment pressure mereases to the RPS'pCIS Inp setpomn I? Secondary t ontamment 1. cal Test This test a perfanned to senfv that the sewndaS mntanunent n capable of mamtammp 0 25 mches of water s acuum under calm un.J con.htions with a litter flow rate of not more than 17H0 cfm l he mstem thit n to be tes'ed n placed m operation All secondary mntamment thiors and notation s ah es are s entied enowd When the Sul ss stem n mamtammp u 25 umhes et water s aeuum m th,.leactor Ilmkhng. the 9 stem 11ou a secorJed Ihm value should be lew than I 780 cfm. which n equa alent to 10W. of the bmhhnp's solume per dat The two Stil trams can then be switched to ensme that the other fan n capable of prouJmp r ted llou V. SYST EM INTERRF.I.ATIONSillPS A lileetncal l'ou er Sources 1.0 ohb 'lhe 460V AC panel MCC R ploudes power to NG I tr,nn A fan ll{ 41-Ilj%R,ll SO 07Jie and the 2 N Lu t 1 Aull-R 1 A-A> anJ 5 0 La e I AU)1.R 1 A ll) heaten 2 l'he IboY AC panel M(Us pioudes ponet m m ! u am 11 fan il < 1 lJ R 11 ! anJ the 2 x Lu 4 I AGil R 11bAi and 5 o Lu ilaull R.1Il lb heatsn LO Mae 1 1he 120Y AC cutwal panel CCp 1 A p;oudo eslool pnuer and solenoid operated t ahe pouer list SO I tran. A

Pagu 24 of 25 1AAMm NLimbert co-302-2e-02 Revisiont c9 4. 1he 120V AC cntical Panel CCP lit proudes control power and solenmd operated valve power for SOT tram 11 5 24V 1)C but Adl) prondes power to the licactor lladding exhaust plenum radiauon momtor A (11) and isuuhary Tnp thats 1.One 6 RPS Adl) providen power to the Oroup 2 ivdauon relavs. Reactor Illdg INhaust Plenum Radiation Detectorn and the Indicator Tnp IJnits 7 CCP 1 A(lll) providen power to the Group 6 isolation relays 4 1.0 06a N CCP.I A proudes power to PC40V-(AD.R I Al and ( AD R lli) 11 Containment isolation and Control Systems 1.045g.10c 1he Su l system receiven mitiation signal iriput trom the cositainmerit iudation and control SO47a system and prondes for autorratic closure and tnpping of normal Reactor lluddmg ventilation RPS power failuren wdl cause the PCIS relan to mitiate SGT system start logie A Group 6 isolation signal causes the ditTerential pressure control valves (SGT DPCW $46A or SGT DPCV 54611) to open unut the signalis reset proudmg their re*pective control switches are m AU10 1.0 05d C l bgh Prenure Coolant injection Sptem S0-07b The SGT system prouden a fdiered flowpath for the discharpe of noncondensible pases accumulated m the llPCI turhine pland seal condenser When 1IPCl mmates automancallt SOT sptem wdl aho imtiate automatically Manual operanon of SGT is required for manual stanup of the llPCI system LO 05h D Plant Air System S0-0?c The plant air tiystem supphes the control air used to operate all of the SUT sutem's dtflerential pressure and flow controllers, as ucll as the air oper ated s ahes 10 0$f li Process Radiation Monitors I hph radiation detected b3 the Reactor lluddmp sentdauon eshaust plenum radianon momtors will start the S01 sptem I.O 05h 1 Pnmary Contamment SOT can take r sucuon fiom the pnmary contamment Suction can be ohpned from either the dirwell or ionis s ent paths 1.0-05a O Reactor liudding Ventdauon so 07f 1he Sul suction is alw an abened to the Reactor limiJmp Ventd.iuan 12Ahaust plenum when sol'is m operauon on a PCls Group 6 mlanon the nonnal Reactor lluddmg Ventilation sutem hohtes and ngl draws an trom the Reastoi ilmldmp 1 0 05e l1 1 les ated telease Pomt Udpas sutem V t he SGT sutem dnchargeuo the i RP tluough two ltr unde: ground hnes When SG l n m operttion the incieased 1 Rp llow causes a sl pht hastprewure on the O!Tras sutem

Pega 25 of 25 I.esson Number: conoo2-28 02 Revisions os Thex SOT discharge hnes can potentially be blmLed ty excesswely high water level in Z surnp located at the base of the l'RP Z sump pumps and sup;mrt eqmpment are essentialin suppon of the SOT sptem g Y_ b pe f

('- ~ Q ). ELEVATED RELEASE POINT l C 1e If Ic Id 1b la g REACTM p ttUILDING g I EXHAUST FETER TR Alti 1 PI ENUM ROOM PRIMARY M CONTAINMEN) p ,,g, AIR FKTER TR AW 2 llPCI TURBINE i GL AND SEAL M' EXilAUSTEH 2e 2s 2c 2d 2b M 2a FAN ? g-' gog4TURE SEPARATOR bC ROUGH PRE-FILTER CC ELECTRec AIR HEATING ELEteENT i d= McGH EFFICIENCY INLET FILTER SC CHARCOAL FETER lC HIGH EFFICIENCY FINAL FILTER t STANDBY GAS TREATMENT (B.asic Flow Diagram) FIGURE 1 REV.4 CxAmmi 1 coa.m., -~

3 -l a ' / M VLOCWED S_; To sc w amco=,iot I_ lh <I ~~ anEase SCTFAMtg PCsNT -Nl g' SGT1 ,uER - v no a E WORTEE g f I twsAst ED AO C 44R Q \\ 80088 A'R '4*:Y)' Q f~ 8 4 / x= a ti f. ses ,,AD#1A RO ~~k--) /, Ao.... h

1 ACTOR

_h __/- #. E

== is %, 2, ev PDatARY CONTMNUE NT / 25. ,f Swf -Ng .m. _2 5""*"" ,s 25C 3

EVtOCMD 5

AO-275

j TO SGT tt,AM Cosmtat

x:

<$h GLAND SEst EM4AUSTER STANDBY GAS TREATMENT (Basic Valve Lineup) RGURE 2, REV. 5

1' g.

) mag,,

g]s) sir ar te OYMEU 037 A sa A4st ~ Lao A4e8 s37 44e8 h ,, r t o w y y t I I s I I A j l lAELAYevg] ftELATIVE ] g [seuesseetvj eeue.estY], j mencveo. i ~~ sesMeemtan ( IE es.IILE TS-43ea [ ~ {-] j Ta j asoggggens opge-es ta IIPse-434A SPeS-83S% SPIS-SSSA E E d W i ggpa.4ygg l l/ f kh hb 8 [ ( ($kfkiii$$ L i f.

1&BG i

/f/, c ;;my y e n / z a "c l FAes j [ y j/j

c-Nut

{ yJ u l i ( f. r a g g, t /7 ig reseeA = , /, [/ .e 3 e. .L.... As. see.g. A. A... see.se p.a reLisa eseAvesse stresseeDCY CAAs.es 00esseE EFF0C8EseCY ELeastesT .EET PETER 8 88888. PseALraven { 49eEPA8 (seEPA) e A-a t so-33 2-34se-al .,s.-...A A -n mv t.,f(Conceact c i 'c i

1..

e,es..,.e. A t

- =

Yo. T. i. STANDBY GAS TREATMENT FILTRATION TRAIN FIGURE 3 REV.4. comeet-, cm e. 1 i I I l I i

R CCP-1 A (CCP-1C) I 1,.. + FROM FAN A (3) MOTOR CIRCUlf t w CONTROL- - +

I Anet g

FIGURE 4a f C"[""># 3I[ o g o AUTO J hg W(AO-252) INITI AT E Af O i SION AL ( AO-2 50) y,, o M.C. 3 GT FILTER TR Al% Ul R.e. ~;; CROSS CONNECT,, ~~ h; AUTO INITIATE SteNAL CONTPOL;.- AIR "W / r i /~ A AO O me o RMS FROM 'T FATEft ' I 2 ll / FROM ygaggg y g y ( A O-2 71)

~

SECONDARY .T5-N C. CONT A 00000ENT r y y y [ es,, _ F O, PRESSURE CONTROLLEn p l 3 i r 3 AUTO IsetTIATE Ste86AL oO TO CONTROL E [ ELEVATED 7; ; ; R404 PO908T j FIGURE 4h 90 ,_r,._. t j ' _rw N C. ~j f~ ~ "g F.O. [ l 9 FROM ePcv l j rR.vER TRAses :) 4a FILTER TRAIN INLET and OUTLET VALVES i 4b REACTOR BUILDING PRESSUEE CONTROL VALVES i FIGURF. 4 REV. 4 c, 3, g

. !( 6 '%'J ) ~ To COOF n OPEN T TO 3GT - 'FRTER TRAM 3 REACTOR AD-R-1C From REACTOR; BUILDING BUEDWG EXHAUST VENTtLATION PLFNUM & EXHAUST HIGH RADIATION In the 7-- RMS j REACTOR BUILDING ^ AD-A-1A

p

^' I EXPAUST PLENUM E I I E g _____,j .P,, 1 AD-R-1B INTERLOCKED with HPCI GLAND SEAL ~ CONDENSER BLOWER f \\ l i a = > " ^ ^ PRatARY CONTANMENT r i EXHAUST VENTILATION LINE FROM HPCI TURGINE GLAND SEAL EXHAUSTER > l A0-275 SGT GUCTION FLOWPATHS Conoc2.a F:GURE 5 REV.4 CxAm,3 e

p. \\ ms w Cooper Nuclear Station improved TS Review Comments ITS 3.6.4.3, Standby Gas Treatment (SGT) System 3.6.4.3 DOC JFDi CHANGE / DIFFERENCE ' COMMENT STATUS Provide additional 1 A.5 2 CTS 4.2 0.4.b discussion and 3 STS SR 1.6.4.3.4 ITC C s 6.4.3.4 and Associated Bases , iustification including boas

n updated SGT 1

Bases CTS 4.7.8.4.b requires demstrating manual OPERABILITY of the System description 5 bypass valve for SGT sticsy3 tams filter cooling. STS SR 3.6.4.3.4 and appropriate P&lDs would meet this CTS regsirement. However, STS SR 3.6.4.3.4 is to show that the modified by ITS SR 3.6.4.3.4 to require verifying the SGT units cross tie conversion from CTS 4.7.0.4.b to ITS SR damper is in the correct position, and each bGT room air supply check valve and SGT dilution air shutoff valve can be opened. In addition, a 3.6.4.3.4 is correct. 1 Note is added to ITS SR 3.6.4.3.4 which specifies that the SR is not required when one SGT subsystem is isolated. Insufficient information is l provided in the justifications and the ITS B3.6.4.3 Bases to assure the I staff that the conversion from CTS 4.7.B.4.b to ITS SR 3.6.4.3.4 is correct. I NPPD will provide a current P&lD, Rev.19 of Dwg. 2037, and a current Student-Text, Rev. O of COROO2-28-02 that NPPD Response: pt ces the system design and operational information into combined format, to show how the present plant interpretation of CTS 4.7.8.4.b is the same as ITS SR 3.6.4.3.4. NPPD requests a meeting to further discuss this issue. See item Number 2 A.13 CTS 1.0.P.2 3.6.4 L ITS LCO 3.6.4.3 i See item Number 3.6.4.1-1 NPPD Response: NPPD will revise the CNS ITS submittal to address the comment. l l '~

OVERSIZE DOCUMENT PAGE(S) PULLED i SEE APERTURE CARD FILES APERTURE CARD / PAPER COPY AVAILABLE THROUGH NRC File CENTER I NUMBER OF DVERSIZE PAGES FILMED ON APERTURE CARD (S) ACCESSION NUMBERS OF DVERSIZE PAGES: 95lloko I63 by6 l l l l. . w..

d- ,,7) (. %/ Cooper Nuclear Station improved TS Review Comments seas _casses ITS 3.6.4.3, Standby Gas Treatment (SGT) System l t 3.6.4.3' DOCi 'JFD? CHANGE / DIFFERENCE

CONNENT STATUS =

l 3 L1 CTS 3.7.8.3 ' Revise the submittal l CTS 3.10.E to show this change l as an Administrative When one SGT subsystem is inoperable, CTS 3.7.B.3 and 3.10.E require change. the diesel generator (DG) for the redundant SGT subsystem be OPERABLE. If this is not met, the CTS definition of LCO requires immediately entering a shutdown path. This requirement is not included in ITS 3.6.4.3 but is moved to ITS 3.8.1, AC Sources-Operating. The justification for this change is designated L1. This is incorrect. The change is an Administrative change. Any changes to the requirements with regard to DG OPERABILITY need to be discussed in ITS 3.8.1, not ITS 3.6.4.3. NPPD Response: The CTS markups and DOC L.1 for CTS 3.7.B.3 and CTS 3.10.E address the described changes in ITS 3.6.4.3, rather than in ITS 3.8.1. NPPD proposes to delete the requirement for the OPERABLE diesel generator as a provision ohe 7-day. Allowed Outage Time for an inoperable Standby Gas Treatment subsystem and, instead, allow 4 hours to take the opt.ra!.Nay actions that ITS 3.8.1 requires. '. NPPD has justified the change, and believes the location of the justification is ccrrect. The change is Less Restrictive due to the deletion and the allowance of additional time to determine the ITS 3.8.1 operability requirements, but NPPD wG revise the CNS ITS 3.6.4.3 submittal and DOC to ensure complete and proper communication and handling of the nature of the change.

O O O Cooper Nuclear Station improved TS Review Comments _cmams ITS 3.6.4.3, Standby Gas Treatment (SGT) System 3'6.4.3-DOCS "JFD ' CHANGE / DIFFERENCE ' COMMENT STATUS-4 L2 CTS 4.10.E Revise CTS submittal L3 ITS 3.6.4.3 R.A. C.1 to show that CTS 4.10.E is modified by CTS 4.10.E. requires periodically verifying the OPERABluTY of the other L3. F'evise SGT subsystem when one SGT subsystem is inoperable during fuel justification L2 to handling operations. This Surveillance Requirement is not adopted in account for the ITS 3.6.4.3. This is not entirely correct. ITS 3.6.4.3 RA C.1 allows unique circumstances the option of placing the other SGT subsystem in operation rather of L3. than suspending fuel handling operations. This is discussed as part of justification L3. Thus even though periodically verifying the OPERABluTY of the other SGT subsystem is not required by the ITS under certain circumstances CTS 4.10.E is used as stated above. I NPPD Response: CTS 4.10.E requires verification of the OPERABluTY of the remaining Standby Gas Treatment subsystem. This verification is an administrative " paper

check. It does not require demonstrating the OPERABlWTY of the remaining Standby Gas Treatment subsystem. Therefore,.NPPD does not consider that ITS 3.6.4.3 Required Action C.1 addresses CTS 4.10.E.

5 Bases ITS B3.6.4.3 Bases - BACKGROUND See item Number 1 3.6.4.1-5 See item Number 3.6.4.1-5. l NPPD Response: NPPD will revise the Bases to reflect the details in CTS 4.7.C.1 (calm wind between 2 and 5 mph). i

/- ~ L( ). ( J- .v v Cooper Nuclose Station Imsaoved TS Review Comments susp ames ITS 3.6.4.3, Standby Gas Treatment (SGT) System 3.6.4.3? DOC' 2JFD2 CHANGE /DfFFERENCE' ' COMMENT STATUS 2 6 Bases ITS B3.6.4.3 Bases - APPLICABLE SATETY ANALYSES See item Number. 1 ITS B3.6.4.3 Bases - REFERENCES 3.6.1.1-5 See item Number 3.6.1.1-5 NPPD Response: The change, identified in the NRC comrrent as being incorrect, was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from "NRC Policy Statement" to *10 CFR 50.36(c)'2)(ii)*) being submitted 13 the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is more correct than the statements approved by the NRC in other recently approved ITS conversions. The difference between the wording of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the r;ference to 10 CFR 50.36(c)(2)(ii)) is a matter of presentat?on preference, is consistent with other reference presentations in NUREG-1433, and has no impact on safety. Therefore, NPPD does not conr.ider a revision necessary. 7 Bases STS B3.6.4.3 Bases - RA A.1 Correct this - 3 ITS B3.6.4.3 Bases - RA A.1 discrepancy. STS B3.6.4.3 Bases - RA A.1 states the following: "In this Condition, the remaining..." iTS B3.6.4.3 Bases - RA C.1 decapitalizes the Ictter *C* in " Condition". This is incorrect. The sentence is referring to Condition A; therefore, the "C"in Condition" should be capitalized. NPPD Response: NPPD will delete the change in a revision to the CNS ITS submittal. However, note that the NUREG-1433 Bases are inconsistent in treatment of this term. The various Bases sections use this same term in the same manner as both " Condition" and " condition." i i l l' l L i

Cooper Nucleer Station improved TO Review Comments 3.op== ITS 3.6.4.3, Standby Gas Treatment (SGT) System 3 6.4.3^ 'DOCI JFD' CHANGE / DIFFERENCE L COMMENT LSTATUS? 8 CTS 3.7.A.2.b Revise the CTS /ITS ITS 3.6.4.3 ACTIONS markup to address CTS 3.7.A.2.b in CTS 3.7.A.2.b allows the Drywell and Suppression Chamber Purge and ITS 3.6.4.3 and Vent Systems to be in operation with the 24 inch supply and exhaust provide appropnate valves open provided that if the venting and purging is through the SGT r*iscussions and System, both SGT trains shall be OPERABLE and only cne SGT train shall justifications for be in operation. Based on the CNS CTS if one SGT subsystem is the retention of this inoperable, then one of the following actions would be taken with regard condition and to venting and purging of containment: associated remedial

a. The Venting and Purging System is realigned such that the measures in 2 inch bypass lines are utilized per the " Note to CTS 3.7.A.2.b, ITS 3.6.4.3 ACTIONS.

b. Venting and purging is suspended until two SGT Systems are See item restored to OPERABLE status, or Numbers 3.6.1.3-1

c. The plant is shutdown in accordance with CTS 1.0.J.

and 3.6.1.3-2. This particular condition is plant specific and is not addressed in the ACTIONS for ITS 3.6.4.3, nor are justifications and discussions provided for not including this condition in ITS 3.6.4.3. See item Number 3.6.1.3-1 and 3.6.1.3-2 for additional concerns with regard to this condition. NPPD Response: With the response to comment 3.6.1.3-1, above, discussing the revision to the Note to ITS SR 3.6.1.3.1, NPPD finds it is not necessary to provide the suggested actions. Not including the suggested actions is equivalent to the approach used in the NUREG-1433 Note 2 to SR 3.6.1.3.2 (i.e, if the affected purge valves are open for reasons other than Note 2 describes, SR 3.6.1.3.2 w:;uld not be met and purging must be immediately suspended or compliance with the provisions of Note 2 must be immediately obtained er the applicable action must be taken.) . em

^ Cooper ph Station improved TS Review Comments ~ n.m== - ITS Section 3.7, Plant Systems 33,y ; DOC h M NOICE C0amlMINT STATUS 11 ' LA.1 ; CTS 3/4.6.H, Shock Suppressors (Snubbers). Please reclassefy this change as an. "R* and modify the justification to. DOC LA.1 states that the snubber requirements of CTS 3/4.6.H address the TS criteria, or provide are to be relocated from the CTS to the TRM, provides a an explanation as to why this ' j justification for the relocation, and states that the relocated. change should not be classified as' requirements are not required to be included in the ITS to provide an "R*.' adequate protection of the public health and safety. Why isn't this change classified and justified as an.*R,* i.e., a true relocated l change? =i i !~ NPPD' Response: Since snubbers support the OPERABILITY of systems credited with mitigating the consequences of DBAs and transients, i they meet Criterion 3 'of 10 CFR 50.36(c)(2)(ii), and an "R* DOC cannot relocate them. Therefore, DOC LA.1 for CTS 3/4.6.H addresses ' i the removal of the snubbers from the CNS CTS. r t j. ? [ i

7y L/ A. -V Cooper Nuclear Station improved TS Review Comments mp.ums ITS 3.7.1, Residual Heat Removal Service Water Booster (RHRSW8) System f 3,7.1 DOC' 'JFD CHANGE / DIFFERENCE. CONNENT STATUS 1-1 CTS 3.5.B STS SR 3.7.1.1 Provide plant specific CTS 4.5.8 ITS LCO 3.7.1 justification for changing 'the ' STS LCO 3.7.1 ITS 3.7.1 Actions A and B nomenclature of the system. STS 3.7.1 Actions C and D ITS SR 3.7.1 - The nomenclature for the systerr in CTS 3.5.8, CTS 4.5.5, STS 3.7.1, LCO, Actions C and D, and SR 3.7.1.1 is Residual Heat Removal Service Water (RHRSW) System. The nomenclature in the ITS is Rasidual Heat 1 Removal Service Water Booster (RHRSWB) System. No justification for the change to the CTS is provided. The justification for the deviation from the STS is that the change reflects plant specific nomenclature. This statement is not consistent with the CTS. i NPPD Response: NPPD will provide an A DOC to address changing the name of the system to match current plant-specific nomenclature. 2 M.2 1 STS SR 3.7.1.1 ITS SR 3.7.1.1 Explicitly state whether the RHRSW system contains STS SR 3.7.1.1 is applicable to manual, power operated, and automatic ~ automatic valves and if it valves in the RHRSW flow path. ITS 3.7.1.1 does not include automatic does, provide justification valves. The justification states that the change is made to reflect plant for not including them in ITS specific system description. This implies that there are no automatic SR 3.3.1.1. l valves in the RHRSW system, bu it isn't explicitly stated. NPPD Response: There are no automatic valves in the system. since the system is manually initiated. 3 3 STS 3.7.1 Required Actions C.1 and D.1 It is the STS convention to ITS 3.7.1 Required Actions A.1 and B.1 place such notes in the Required Action column. The marked up copy of STS 3.7.1 indicates that the note for Required Please revise the STS markup Actions C.1 and D.1 are repositioned in ITS 3.7.1 Required Actions A.1 and eliminate JFD 3 to be and B.1 to be consistent with the Writers Guide. However, the notes are consistent with the smooth. not repositioned in the smooth copy of ITS 3.7.1. copy of the ITS. NPPD Response: ' NPPD will revise the ISTS markup to match the typed copy of the ITS.

p p Coo,er uc , ct. tion i.prov., u R ie. - ITS 3.7.1, Residual Heat Removal Service Water Booster (RHR$WB) System 3 ;7.1 ' ' DOC . 'JFD ~ CHANGE / DIFFERENCE COMMENT STATUS f 4 L1 2 CTS 3.5.B.1 STS 3.7.1 Actions A and C This change is beyond the CTS 3.5.B.2 ITS 3.7.1 Actions scope of the conversion review and has been referred Both the CTS (CTS 3.5.B.1. CTS 3.5.B.2) and STS 3.7.1 Action A allow to the Project Manager for i l thirty days to restore an inoperable RHRSWB pump. STS 3.7.1 Action C resolution. f is an additional requirement to address one inoperable RHRSW system for reasons other than an inoperable RHRSW pump. ITS 3.7.1 does not include the condition of one inoperable RHRSW pump nor the STS allowance to restore in 30 days. The justification states that only one i pump in each subsystem (2 pumps) is required by the analyses. This j ju::tification is based, in part on GENE 637-045-1293. This is a change j to both the CTS and STS. ' NPPD Response: No rerponse required. NPPD considers this comment to be for internal NRC issue tracking purposes. 5 M.1 CTS 3.5.B.3 ITS 3.7.1 Required Actions A.1 and 8.1 Explain why you would not enter the Actions for an The proposed change adds a note requiring the applicable Conditions and inoperable RHR SDC - Required Actions of LCO 3.4.7 to be entered for an RHR SDC subsystem subsystem in the same made inoperable by the inoperable RHRSWB System. The justification circumstance under your states that this is a More Restrictive change because it is an added CTS. The staff does not requirement to cascade to LCO 3.4.7. believe that this is a More Restrictive change. NPPD Response: The CNS CTS does not include requirements for the RHR Shutdown Cooling System. Therefore, there are no RHR Shutdown Cooling System actions to enter in the event the RHR Service Water Booster System is inoperable and this results in an RHR Shutdown Cooling Systems being inoperable. I l l l l

~ s Cooper Nuclear Stoelen improved TS Rowlew Comments m p osee ~ i: ITS 3.7.2, Service Water (SUIO and UNimoes Heat Sink (UMS) g 4 ,a ~ J -N*- 6 2-STATUS 17.2t M IM O' ^

1.

L4 - CTS 3.12.C.2 Revise tho'- ITS 3.7.2 justification to ' L ITS 3.8.1 Required Action B.2-correctly state ll the CTS a, With any inoperable active component that affects operability of one SW requirement.. = subsystem. CTS 3.12.C.2 requires that all active components that affect operabihty of the operable subsystem (the other subsystem), including the associated DG, be - j operable.. These requirements are deleted in ITS 3.7.2 but are included in ITS 3.8.1 - ~! Required Action B.2.) The justification for this change incorrectly states that the' I c CTS requires ensuring operability of required features in the same devision as an i s -j ~ inoperable DG. The CTS actually requires ensuring operability of required features in P the same division'as the operable DG. 1 I-I ~! I NPPD Response: NPPD will revise DOC L4 for ITS 3.7.2 to change " inoperable DG" to " Operable DG". J l _2 2 STS 3.7.2 Required Action D.1 Revise the 1 j ITS 3.7.2 Required Action A.1 submittal to - adopt the STS.. [ The bracketed words "RHR shutdown cooling"in STS 3.7.2 Required Action D.1 are wording. l: modified in ITS 3.7.2 Required Action A.1 to *RHR shutdown cooling subsystem." l_ The justification provided for this change does not appear appropriate and the > change makes the wording of this note inconsistent with the wording of similar notes in other specifications (i.e., ITS 3.7.1).- t NPPD Response: NPPD will revise the CNS ITS submittal as suggested in the comment. f j n 4 I I l l

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Cooper Nucleer Station improved TS Review Cv...ii-.ts sn.c=ms ITS 3.7.2, Service Water (SW) and Ultimate Hest Sink (UHS) 3,7.2 ' DOC'~ JFD CHANGE / DIFFERENCE - ' COMMENT ' STATUS 3 L1 5 CTS 3.12.C.2 This change is STS 3.7.2 Required Action D.1 beyond the scope ITS 3.7.2 Required Action A.1 of the conversion review and has CTS 3.12.C.2 allows continued operation for 30 days with one inoperable SW been referred to pump. With one SW subsystem (two inoperable SW pumps) the CTS requires the Project shutdown to Mode 4 within 36 hours, STS 3.7.2 Required Action D.1 allows Manager for operation to continue indefinitely with one inoperable SW pump and continued resolution. operation for 72 hours with one inoperable SW subsystem. If STS Required Action D.1 is not met STS Required Action E.2 requires shutdown to Mode 4 within 36 hours. This is modified by ITS 3.7.2 Required Action A.1 to allow continued operation for 7 days with one incperable SW subsystem. The ITS changes both the CTS and the STS. In addition ITS 3.7.2 Required Action A.1 extends the CTS Completion Time for shutdown by 7 days. NPPD Response: None required at this time. 4 L.1 2 CTS 3.12.C.2 and C.3 This change is STS 3.7.2 Actions A, B and D beyond the scope ITS 3.7.2 Actions of the conversion review and has CTS 3.12.C.2 and 3.12.C.3 require all SW pumps to be operable and provide actions been referred to if one or two SW pumps are inoperable. STS 3.7.2 Actions A (also referenced in - the Project Action D) and B have Required Actions if one SW pump is inoperable or if one SW Manager for pump in each subsystem (two SW pumps inoperable). These Actions are not resolution. retained in ITS 3.7.2. This is a change to both the CTS and STS. NPPD Response: None required at this time.

p Cooper Nuclear Station improved TS Review Comments ~ sn.cas m ITS 3.7.3. Reactor Equipment Cooling (REC) System 3.7.3 ' ' DOC - JFD ' CHANGE / DIFFERENCE CGMMENT ~ STATUS 1 L1 4 CTS 3.12.B.1 and B.2 STS 3.7.2 Actions A and B This change is ITS 3.7.3 Action A beyond the' scope of the conversion CTS 3.12.B.1 and CTS 3.12.8.2 allow 30 days to restore and inoperable REC review and has pump. STS 3.7.2 Action A provides the same 30-day allowance for an inoperable been referred to pump. This requirement is replaced in ITS 3.7.3 Action A to allow 72 hours to the Project restore one inoperable REC subsystem. The justification states that the change is Manager for based on the fact the either REC loop has sufficient capacity with one pump resolution. operating to transfer the essential services design cooling load during postulated transient or accident conditions. The justification also states "If one of the two subsystems is Inoperable, currently no time is allowed and a shutdown is required." This statement appears to be incorrect because CTS 3.12.B.2 allows an inoperable active component for 30 days if the other subsystem, the Core Standby Cooling Systems, and the associated DG are operable. This is a change to both the CTS and the STS. NPPD Response: None required at this time. 2 L4 CTS 3.12.B.2 ITS 3.7.3 Correct the justification and CTS 3.12.B.2 contains requirements to ensure that all active component that affect the CTS markup. operability of the ECCS Systems and the DG associated with the operable subsystem are operable. These requirements ar2 not retained in ITS 3.7.3. The justification incorrectly refers to the RHRSWB pumps instead of the REC pumps. Also, the CTS markup does not incorporate all of the text related to this change (i.e., text referring to the operability of the Core Standby Cooling Systems). NPPD Response: NPPD will revise the justification and the CTS markup as suggested in the comment.

V U w/ Cooper Nuclear Station improved TS Review Comments m_ cme.nes ITS 3.7.6, Spent Fuel Etorage Pool Wtter Level 3,7.6 - DOC JFD l ' CHANGE / DIFFERENCE ' COIWIWENT + -STATUS 1-L1 CTS 3.10.C Provide additional discussion that ITS 3.7.6 Applicability addresses how minimum water level will be maintained when fuel I-CTS 3.10.C states that the applicability is whencver irradiated assemblies are not being moved fuelis stored in the spent fuel pool. ITS 3.7.6 states that the after ITS implementation (i.e., what applicability is during movement of irradiated fuel assemblies in is happening to the CTS requirement the spent fuel storage pool. The justification (and the Bases) is for this situation). based on satisfying the analysis of the fuel handling accident but does not address how water level is maintained when fuel assemblies are not being moved. NPPD Response: NPPD will revise DOC L1 for ITS 3.7.6 to discuss the plant-specific administrative controls to ensure rnaintaining spent fuel pool water level.

_.n - }. ; Y .3 Cooper Nucteer Stesion improved TS Rewtow Comments L m casses ITS 3.7.6, Spent Fuel Storage Pool Water Lavgi j 317.6l DOC W ND COEMENT STATUS j u ' 2 --- A.2 . Bases CTS 3.10.C Provide addstional d===k=t of thel -2 ITS LCO 3.7.6 and associated Bases. fuel handing accident analysis. assurr.ptions that demonstrate that - CTS 3.10.C specifies that scent fuel pool level be maintained the ITS value is the appropriate 8.5 ft above the top of the fuel. ITS LCO 3.7.6 requires that technical specification limit. I spent fuel storage pool water level be 2 22 ft 5 inches over the [ top of the irradiated fuel assemblies seated in the spent fuel

{

storage pool racks. The justification states thet 8.5 ft above t I a bundle being Sandled by' the refuelmg bridge grapple is jl l' approximately 22 ft 5 inches above the top of irradiated fuel seated in the spent fuel pool. 'Also, the Background section of the Bases for ITS 3.7.6 states that the water level above the l irradiated fuel assemblies is an kripdicit assumption of the fuel I handling acculent. The STS Bases refer to the water level as. an explicit assumption. r I ' I i NPPD Response: USAR Section X-3.4.1 defines the ' safe storage level" of the water in the spent fuel storage pool as approximately. i 10 feet above the top of the fuel." The " safe storage level"is based on the water volume assumptions for the iodme decontammation' { factor in the fuel handling accident analysis. Therefore, the CNS ITS 3.7.6 water level limit of at least 22 ft 5 inches over the top of .] j' irradiated fuel assemblies seated in the spent fuel storage racks is more than that required for " safe storage level.* Allowing for an. .} adequate 6-in. clearance between a moving fuel assembly and those seated in the racks, the 22-ft-5-inch level is sleghtly more than 8.5 ft _ 1 l above the top of the irradiated fuel in the moving fuel assembly. Therefore, this preserves the current licensing basis in the CTS. '*lmplecit" l is correct because the " safe storage level"is not part of the limiting fuel handling accident analysis over the reactor core, which assumes a ' water volume, not a level, for the decontamination factor assumptions.

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1 L O ) O re ph Stedon improved TS Review Comments mpa=en - ITS 3.8.1, AC Sources - Operating y Q

1-L1 CTS 3.9.B.1.b '

Provide additional ITS 3.8.1 Action C d%cussion and justification for deleting the l CTS 3.9.8.1.b requi es verifying operability of the diesel requirement. generators and associate.d critical buses.' ITS 3.8.1 Action C does not require verifying the associated critical buses are OPERABLE. No discussion or justification is provided for deleting this requirement. i NPPD Response: If the critical buses are not OPERABLE, then the supported features powered from the critical buses would also not be OPERABLE. Therefore, ITS 3.8.1 Required Action C.1 addresses this condition, and complying with these requirements implicitly requires veri,fying that the critical buses are OPERABLE. NPPD will revise DOC L1 for ITS 3.8.1 to clarify this. I { 2 2-STS SR 3.8.1.2 Note 2 This is not a justifiable ( ITS SR 3.8.1.2 Note 2 plant-specific or editorial . [ difference. Revise the t STS SR 3.8.1.2 Note 2 indicates that a modified start may be used submittal to adopt the STS for this SR as recommended by the manufacturer. When modified wording. start procedures.:ee not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be used. The corresponding note in ITS SR 3.8.12 states that a modified start may be used for this SR consistent with the manufacturer's recommendations. When modified start procedures are not used, the time, voltage, and frequency requirements of SR 3.8.1.7 must be used. These changes in wording are not justified. NPPD Response: NPPD chooses to maintain the CNS current licensing basis with respect to control of these values. About the changes to the Notes, NPPD will revise the CNS ITS submittal to reflect the STS wording, except for " requirements"instead of " tolerances," which JFD 1 justifies. NPPD will also revise JFD 2 and remove its application at this point, and change JFD 3 to include justifying the renumberina of the NOTES in ISTS SR 3.8.1.2. t wp p.- w g-em e.,, w -- -. u 3 +upie.,'-s' i- --w

3 m 3 Cooper Nuclear Station Improved TS Review Comments m_c== ITS 3.8.1. AC Sources - Operating 3 n'1 - ' rme ~.FD cHANf3fDIFFFRFNfT t'f N KTAT11R 3 A.11 CTS 1.0.J Revise the submittal with CTS 3.9.B.1 a L-type DOC to justify the CTS 3.9.B.2 longer shutdown ITS 3.8.1 Condition G Completion Times. CTS 3.9.B.1 and 3.9.B.2 do not provide Actions for the condition of three or more AC sources inoperable. However CTS 1.0.J requires being in Mode 3 within 6 hours and Mode 4 within 36 hours when either the emergency or normal AC power sourc7 for one train of a system is inoperable and the redundant train of the system is inoperable G>ecause of an inoperable support system or because the system itself is inoperable or because one of its AC sources is inoperable). ITS 3.8.1 Condition G is added to direct entry into LCO 3.0.3 for the condition of three or more AC sources inoperable. ITS LCO 3.0.3 requires being in Mode 3 within 13 hours and Mode 4 within 37 hours. This is a less restrictive change because an additional hour is allowed to complete the shutdown. NPPD Response: As DOC A.11 for ITS 3.8.1 discusses, DOC L1 for ITS 3.0.3 justifies the change to CTS definition of LCO (CTS 1.OJ), which provides the additional time periods in ITS LCO 3.O.3. Thus, the justification for the change to CTS 1.OJ does not need repeating. 4 A.4 3 CTS 4.9.A.2.a.1 Revise the submittal to CTS 4.9.A.2.a.2 adopt STS SR 3.8.1.2 STS SR 3.8.1.2 Note 1 Note 1, which is ITS SR 3.8.1.2 consistent with CTS. CTS 4.9.A.2.a.1 and CTS 4.9.A.2.a.2 state that CTS 4.9.A.2.a.2 '(DG timed start test), satisfies CTS 4.9.A.2.a.1 (DG modified start test). This statement is omitted from corresponding ITS SR 3.3.1.2, the modified start test. This results in a STS deviation because STS SR 3.8.1.2 Note 1 states that performance of SR - 3.8.1.7 satisfies SR 3.8.1.2. The justification for deleting this ' statement from the CTS and STS is not plant specific or editorial. NPPD Response: NPPD will revise the CNS ITS submittal as suooested in the comment.

-m o n U U U Cooper Nucleer Station improved TS Review Comments an c== nes ITS 3.8.1, AC Sources - Operating NTAT g 1 R 1" DOC ~ OFD CHANCF/nAFFFRFNr'r ' t'namacarT 5 M.b 8 CTS 4.9.A.2.a.1 Revise the submittal to CTS 4.9.A.2.a.2 include specific load values STS SR 3.8.1.3 in SR 3.8.1.3, consistent ITS SR 3.8.1.3 with the STS and the ' assumed accident load *. CTS 4.9.A.2.a.1 and CTS 4.9.A.2.a.2 state that each diesel shall in the response, state the be started and loaded to 2 50% rated load. ITS SR 3.8.1.3 states ' assumed accident load

that the EDG is loaded to greater than the ' assumed accident and where it is stated in load'. This differs from STS SR 3.8.1.3 which indicates, by the Bases.

brackets, that plant-specific load valoes should be provided. DOC M.5 states that the specific values are in plant procedures and the Bases. The only load values given in the Bases are in the Bases 8ackground discussion of DG load. Orne ratings. It is unclear which of these correspond to th, m.aaed accident load'. NPPD Response: DOC M.5 for ITS 3.8.1 justifies the use of and provides the values for the " assumed accident loads." JFD 8 justifies not including specific load values in ISTS SR 3.8.1.3 and says that plant procedures and the Bases have the specific load values. NPPD will r; vise the Bases of ITS SR 3.8.1.3 to include these accident loads. NPPD chooses to maintain the CNS current licensing basis with respect to control of these values. 6 M.10 8 CTS 4.9.A.2.a.1 & 4.9.A.2.a.2 Revise the submittal to l STS SR 3.8.1.2 & SR 3.8.1.7 include specific voltage ITS SR 3.8.1.2 & SR 3.8.1.7 and frequency values in SR 3.8.1.2, consistent with CTS 4.9.A.2.a.1 states that each diesel shall be started and loaded the STS and the current for greater than 2 hours. ITS SR 3.8.1.2 requires starting the EDG licensing basis. and achieving rated voltage and frequency. This differs from the STS SR 3.8.1.2 which indicates, by brackets, that plant specific values for frequency and voltage should be provided. JFD 8 states that the specific values are already in plant procedures and will be added to the Bases for ITS SR 3.8.1.2 and SR 3.8.1.7. NPPD Response: DOC M.10 for ITS 3.8.1 justifies the addition of " rated voltage and frequency

to the current licensing basis defined in the CNS CTS. JFD 8 justifies not including specific values in ISTS SRs 3.8.1.2 and 3.8.1.7 and says that p! ant procedures and the Bases

f. ave the specific values. NPPD will revise the Bases of ITS SRs 3.8.1.2 and 3.8.1.7 to include these values. NPPD chooses to maintain the CNS current licensina basis with respect to control of these values.

,b b Cooper Nuclear Station improved TS Review Comments m _c*m m ITS 3.8.1, AC Sources - Operating 't st 1 - nOC MD - CHAMMFiiWiHFNCF FP"- --*"Y MTATtM 7 L5 2 CTS 4.9.A.2.a.1 These are not justifiable L9 9 STS SR 3.8.1.3 Notes 1 and 2 plant-specific or editorial ITS SR 3.8.1.3 Notes 1 and 2 differences. Revise the submittal to adopt STS SR Note 1 to ITS SR 3.8.1.3, DG load test differs from STS 3.8.1.3 3.8.1.3 Notes 1 and 2. Note 1 by stating that ' gradual loading is permitted consistent with See comment 3.8.1-05. the manufacturer's recommendations

instead of stating that

' gradual loading is permitted as recommended by the manufacturer.' Also,11S Note 2 differs from STS Note 2 by replacing 'outside the load range' with 'below the required limit.' NPPD Response: NPPD will remove the application of.;FD 2 in NOTE 1 of ISTS SR 3.8.1.3 and use the STS nemenclature as capturing the typical nomenclature in the current licensing basis of the CTS. Conceming NOTE 2 of ISTS SR 3.8.1.3, the JFD 9 change goes along with the JFD 8 cht;nge to ISTS SR 3.8.1.3: with a " greater than* SR reauirement statement, thare is no range outside of which to go; thus, NOTE 2 only needs a "less than" allowance. 8 M.12 8 CTS 4.9.A.2.b Revise the submittal to STS SR 3.8.1.19 include specific voltage ITS SR 3.8.1.11 and frequency values in SR 3.8.1.11, consistent with CTS 4.9.A.2.b requires demonstrating that the diesel will start and the STS and the current accept the emergency load within the specified time sequence but licensing basis. does not specify voltage and frequency requirements. ITS SR 3.8.1.11 c.2 and c.3 specify that rated voltage and frequency t must be achieved. This differs from STS SR 3.6.1.19 which indicates, by brackets, tSat plant specific values for frequency and voltage should be provided. JFD 8 states that the specific values are in plant procedures and are added to the Bases. NFPD Rescense: NFPD chooses to maintain the CNS current licensina basis with respect to control of these -alues.

), j. .~s .7s ( Cooper Nucteer Station loproved TS Review Comments m_cmems ITS 3.8.1, AC Sou:ces - Operedng l = 3 se i noc' "En cmmacrine+mrascr - rr - - =T ETATtne 9 M.12 6 CTS 4.9.A.2.b Provide justifecation for STS SR 3.8.1.19 this STS deviation based ITS SR 3.8.1.11 on current licensing basis, system design, or CTS 4.9.A.2.b requires demonstrating that the Gesel will start and operational constraints. accept the emergency load within the specifed time sequence but does not specify how long the EDG must supply the loads during the test. ITS SR 3.8.1.11 c.4 specifies that the EDG must supply only the auto-connected emergency load for 2 5 minutes. This differs from STS SR 3.8.1.19 which requ res that the EDG supply both the permanently connected and auto-connected emergency loads for 2 5 minutes. No justification is provided for omitting permanently connected emergency loads from 15e requirement. NPPD Response: Because ITS SR 3.8.1.11 c.1 and the Bases for ITS SR 3.8.1.11 both refer to permantently connected loads, NPPD will ravice the CNS ITS SR 3.8.1.11 c.5 to delete the application of JFD 6 here and to retum to the STS SR 3.8.1.19 c.5 wording. Note that the Chance / Difference section refers to ITS SR 3.8.1.11 c.4 instead of ITS SR 3.8.1.11 c.5. I 1m.

v g -.V _r. i Coops, mus eer st en i.pr.eed Ts Re.ie. comments a

ITs 3.s.1,' Ac sources - opereeng i

L M '. W ' f=-gPQ lg&_'=% } WM ~ ; w i 4,g %jf 3 @===g___ _ _ _=_ ; l 10-M.8 112l

STS' SR 3.8.1.14 Revise the subrmttet to 1 Check utdt

~ ITS SR 3.8.1.9 adopt STS SR 3.8.1.14 ET. : with a 24-hour load test. ITS SR 3.8.'.3 is a new requirement to load test the DG for at : and lood value ranges l l -least 8 hours where 2 of the hours are at 105% to 110% of the. specified in kW. ' '{ - continuous rating and the remaining hours are at 90% to 100% of the continuous rating. ITS SR 3.8.1.9 differs from STS SR 3.8.1.14 which requires (1) a 24 hour test with 2 hours at a F specified load range and the remaining hours at another 'specified .s. - load range; and (2) stating plant-specific load values in kW. JFD ~ 12 bases the 8-hour test on IEEE Standard 387-1995, Section j 7.5.9 and Table 3 for cyclic testing, wting that a 24-hour test is only recommended for preoperational testing. Staff does not agree with this justification. In addition, plant-specific load values ira kW should be specified in the SR itself, not only in the Bases. - i L .i NPPD Response: Since the CNS CTS does not include a Surveillance similar to this one, this is a More Restrictive change. The 24-hour DG endurance run represents a hardship, since it has to be run with the plant shut down (adds critical-path time to each refueling outage). t l NPPD does not wish to adopt the 24-hr run requirement.. In addition. NPPD chooses to maintain the CNS current licenseg basis with respect to control of these load values. 11 M.8 6 STP, SR 3.8.1.18 Revise ITS SR 3.8.1.10 to - ITS SR 3.8.1.10 include a plant-specific y i acceptance limit expressed 1l ITS 3.8.1.10 is a new requirement to verify that the interval as a percentage of the between each sequenced load is 'within specified limits' for the design interval. jl timed logic sequence. ITS SR 3.8.1.10 differs from correspondmg i' STS SR 3.8.1.18 which specifies that the interval must be '*10% ' of design interval'. The "i10% of design interval' is a bracketed l item where the plant specific value is *o be entered. JFD 6 does .not spoofically discuss substituting "within specified limits" for a .1 j specific percentage limit. i NPPD Response: Since the CNS CTS also does not include this Surveillance, it is a More Restrictive change. As the CNS CTS does not Yi ' include specific acceptance criteria. NPPD chooses to mamtsin the CNS current licensina basis with respect to control of these limits. i k ~~ s

3 .e i Cooper Nucteer Steelon igigirowed TS Rowlow Comments {

cassus ITS 3.8.1, ' AC Sonnees - Operosing l

q,p Q Q. ' y; J yng _-Jg qp - __; 'j= ig g ~ 1 12

2

~ STS LCO 3.8.1 c1 Revise JFD 2 to explicitfy - STS 3.8.1 Action F - state how the reviewer's j i ITS 3.8.1 note for'not adopting STS .i 3.8.1 Action F 's satisfied. STS 'LCO 3.8.1' c requires three automatic sequencers and STS Otherwise, adopt STS LCO .j 4: -3.8.1 Action F applies to one automatic load sequencer inoperable 3.8.1 c and Action F. 1 l' 1 (these are bracketed items). ITS 3.8.1 does not adopt these . requirements for automatic sequencers. JFD 2 states that these "4[ l bracketed items are not applicable to CNS, but does not explain-l why. t j 4 NPPD Response: Since the CNS design does not include load sequencers such that an individual load sequencer inoperability will impact ' both the OPERA 8ILITY of an offsite source and the DG associated with a given emergency bus, NPPD will add a new JFD to discuss tfiis f i snd appropriately annotate the CNS ITS submittal to replace JFD 2 'm these two locations. l '13 2 . STS SRs 3.8.1.4,' 3.8.1.5, and 3.8.1.6 ' Revise the submittal to r 'I ITS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6 explicitly confirm whether i or not CNS DGs have i i STS SRs 3.8.1.4,3.8.1.5, and 3.8.1.6 indicate that surveillances engine mounted tanks.. If - are to be performed on engine mounted tanks (this is a bracketed : they do, adopt the'STS L j i item). Requirements for engine mounted tanks are not adopted in requirements. } corresponding ITS SRs 3.8.1.4, 3.8.1.5,' and 3.8.1.6. JFD 2 j contains no specific information to exp'.ain why these requirements j are not appiscable to CNS. l i. NPPD' P :;.w: Since the CNS DG fuel oil system design does not include separate engine mounted tanks, only day tanks and fuel oil storace tanks. NPPD will add a new JFD and annotation to discuss this. "l l' 4 i 't i l G l

m J Cooper Nuclear Station improved TS Redew Comments ac_cmase. ITS 3.8.1 AC Sources - Operating 4af on6 'cHammrir-+mm.cr - rr-m nraram 14 10 STS SR 3.8.1.9 ' single-largest-load rejection by DG Note: Comment is lettered STS SR 3.8.1.10 full load rejection by DG the same as the reason. STS SR 3.8.1.11 DG start on LOOP STS SR 3.8.1.12 DG start on ECCS initiation Comment for reasons (a), STS SR 3.8.1.13 automatic DG trip bypass test (b), (c), (d), (e), (h), (I), (k). STS SR 3.8.1.15 DG hot-restart and load test (I), and (m).: This is likely - STS SR 3.8.1.16 transfer of loads from DG to offsite circuit true for most facilities:. STS SR 3.8.1.17 automatic return of DG to standby mode thus this reason is generic, from test mode upon an ECCS initiation signal not plant-specific. STS SR 3.8.1.20 simultaneous start of both DGs Except for SR 3.8.1.17, ITS do not adopt the listed SRs because they do not which tests a feature not ~ " materially contribute to the demonstration of DG Operability." in the Cooper design, no This conclusion is based on the following reasons: plant-specific reasons are given for not adopting (a) test of non-credited design feature these surveillances. - SR 3.8.1.9 SR 3.8.1.10 SR 3.8.1.13 SR 3.8.1.16 Revise the submittal to adopt these requiremenks. (b) other DG is adequate to mitigate DBA SR 3.8.1.9 (c) consequences of overspeed bounded by failure of UG itself SR 3.8.1.10 (d) operator action eequired regardless of overspeed, but not assumed for first 10 minutes after DBA SR 3.8.1.10 SR 3.8.1.16 (e) combined LOOP-LOCA test (ITS SR 3.8.1.10) bounds separate tests SR 3.8.1.11 SR 3.8.1.12 (f) not consistent with current test practices (CTS 4.9.A.1.a (f) CTS specify separate and 4.9.A.1.b). LOOP and LOCA tests,' SR 3.8.1.11 SR 3.8.1.12 apparently in conflict with ' current test pract ces.' i continued continued ,n.. m,

4 L Cooper Nuclear Station improved TS Review Comments ~ ns.aees ITS 3.8.1, AC Sources - Operating ' sa1 rmc wn cwamuwsrwr+m m s rr- =i

straTim 14 (continued)

(continued) contd.. (g) not consistent with current test practices.' -(g) Adding these test SR 3.8.1.15 SR 3.8.1.20 requirements is not inconsistent with current (h) Hot restart capability demonstrated during initial plant testing practice, since they startup testing. are not currently done. SR 3.8.1.15 (i) Monthly start and load test adequately demonstrate ability to operate and start at normal operating temperatures - the DG is designed to start when " hot". SR 3.8.1.15 j (j) Not consistent with current test practices. (j) It appears that. SR 3.8.1.17 automatic realignment to standby mode is not part (k) DGs do not perform any safety-related function for of design, so it cannot be a LOCA event (i.e., ECCS initiation), when offsite sources tested. Thus, this reason I remain available. is pant-specific and t SR 3.8.1.17 acceptable. (I) Current licensing basis does not require postulating that a LOOP occurs some time subsequent to when a LOCA occurs. SR 3.8.1.17 i (m) Separation and independence are part of the design and thus do not need to be verified by [pariodic] testing; they are ensured by configuration control and existing maintenance practices. SR 3.8.1.20 NPPD Response: Since the CNS CTS does not include Surveillances similar to the ones addressed in this comment, the addition of these requirements would constitute More Restrictive changes. As the subject Suiveillances are net part of the current licensing basis _ reflected I in the CTS, NPPD does not choose to adopt these requirements in the CNS ITS. D i .-m,

.n ) a..

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p., Nu , St. den in.r d TS eer - r, - ITS 3.8.2f 'AC Sources - Shutdown ,. h 1 ^ - C"A"'at m u ~ ~ ~ *, .!)jC 2STAftR- ./., E

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9, COREIM!NT- @ a4" - DOC JM q L1- '3 ' STS 3.8.2 Action A Note This generic difference is 1 ITS 3.8.2 Action A Note consistent with the STS - Beses for Action A and STS Action A Note states "....with one requirsd division de.. appears =-- ;^Ji. NPPD is ~ energized.. " L The corresponding note in the'ITS states ".. when request.d to propose a, lf 1 any division is de-energized...." JFD 3 h this difference on generic change to tim STS as avoiding a possible rnisinterpretation that the note would not., a condition of adopting this apply if rnore than one division is de-energized as a result cf difference in the ITS. l Condition A. This is not a plant specific basis. ~ j i NPPD Response: NPPD will develop a generic change to the STS, as suggested in the comment. ? i -i k ~ 5 ) i b -l l 't I s .,b ,-y a o 7 m . v 2 t....s'rr m-a - m e m a.u. m 2 m e-. .. --m... -- m..

t l' Cooper Mar 4=ar Ctesion improved TS Review Comments ses.cmames ITS 3.8.7, ~ AC Sources - Shutdown I ~ r VN 13.81- .fDOC? W? '~ Y ^ f CSaN ~ ' STATULF~; 2

ITS 3.8.2 Actions Note This note is unnecessery. -

1 TSTF-36 Revise the submsttal to omit l this note. - I ITS propose a note to the Actions that says LCO 3.0.3 is not n applicable. This' difference from the STS is based on TSTF-36. This Note should also be - ~ NRC rejected TSTF-36 and its first revesion. The TSB reviewer removed from ITS 3.8.5 and i has recommended rejection of Revision 2. 3.8.8. j r i NPPD Response: The proposed Note to the ITS 3.8.2 ACTICNS provides a necessary clarification, because defaulting to ITS.LCO 3.0.3 (during irradiated fuel assembly movement in MODE 1, 2, or 3) would require the reactor shut down, but would not require immediate suspension'of movement of irradiated fuel assemblies when required components are inoperable. ITS LCO 3.0.3 is only applicable in MODE 1, 2, or 3. Therefore, once the unit is in MODE 4 in accordance with ITS LCO 3.0.3, ITS LCO 3.0.3 is no longer applicable. t The actions of the " shutdown" Electrical Power System %hnical Specifications (i.e., ITS 3.8.2 ACTIONS), which require suspendon of' I irradieted fuel movement, wou8d then be applicable. Hove.sver, the requirements of ITS LCO 3.0.3 would allow up to 37 hours to place the un;* % MODE 4 iand as a result up to 37 hours would be allowed to suspend irradiated fuel movement). Therefore, with the unit in this l Ccndition, the Note, "LCO 3.0.3 is not applicable," ensures that the actions for requiring immediate suspension of movement of irradiated fuel assemblies are not postponed due to entry into ITS LCO 3.0.3 and that the unit is immediately placed in a rt ndition of minimum risk, - l with respect to fuel handling activities during MODE 1, 2, or 3. A revision to genc-ic change Technical Specification Task Force (TSTF)-36 4 h s been proposed to reflect this information. ) 3 1 ITS SR 3.8.2.1 Make appropriate changes. 1 i STS SR 3.8.2.1 upon resolution of comment q 3.8.1-14. The listed SRs of ITS 3.8.1 omit the SRs of STS 3.8.1 that CNS 'i h does not propose to adopt. F NPPD Response: Since the CNS CTS does not include Surveillances similar to the ones addressed in this comment, the addstion of these 1 requirements would constitute More Restrictive changes. As the subject Survedlances are not part of the current licensing basis reflected i d in the CTS,1 NPPD does not choose to adopt these requirements in the CNS ITS. j i i I a I' i + I 3 e s a ,,x a a w .u- +w. r -w +, .w..v,--a-rn..m n..m

Cooper Nuclear Stadon improved TS Review Comments . mpiues ITS 3.8.3, Diesef Fuel CE, Lube Oil, and Starting Air r f e <1 n 1 noc' En - c Hanstwii gskii. irs - rr m travant- - 1 A.2 . CTS 4.9.A.2.d ITS SR 3.8.3.3 Adding the centrifuge test CTS 4.9.A.2.e ITS 5.5.9 for new fuel is a difference Bases for ITS SR 3.B.3.3 from the STS and a change DOC LA.3 for ITS Serion 5.5 to the CTS. Thus, it is a JFD 25 for ITS Section 5.5 beyond scope change. Bases JFD 6 for ITS Section 3.8.3 Ed Tomimson or EELB TSTF-106 (approved) must review it. ITS 5.5.9, Diesel Fuel Oil Testing Program, and ITS SR 3.8.3.3, which requires verifying fuel oil properties in accordance with ITS 5.5.9, replace CTS 4.9.A.2.d and 4.9.A.2.e. ITS 5.5.9 establishes the diesel fuel oil tests the program must include. But certain details, such as the surveillance test inierval for new fuel oil parameters of density, kinematic visensity, flash point, and appearance, are moved to the Bases for SR 3.8.3.3 and the Diesel Fuel Oil Testing Program itself, outside TS. As discussed in JFD 25 for ITS Section 5.5, ITS 5.5.9.a.3 (and associated Bases discussion of SR 3.8.3.3) allow an alternate test for verification of acceptability of new fuel (prior to addition to the storage tank) with regard to water and sediment contern - I the ASTM-D975-1989a water and sediment by centfuge test - in lieu of the ASTM-D4176-1991 clear and bright test as specified by CTS 4.9.A.2.e.1.d. l [ i4 PPD Response: The CNS DG fuel supplier provides dyed fuel oil. The water and sediment by centrifuge test was put in the Bases because the CTS 4.9.A.2.e.1.d requirement to perform the clear and bright test to determine water and sediment content is not r: commended for use with dyed fuel oils. During the NRC's Peach Bottom ITS conversion reviews, this same issue about which test to use to determine water and sediment content t,f dyed fuel oil was discussed. At that time, Ed Tomlinson (NRC Technical Specification Branch) took the position that the clear and bright test was not appropriate to use to determine water and sediment content of Jyed fuel oil and he r; commended that the Peach Bottom ITS submittal be revised to allow the option of using the water and mediment by centrifuge test on dyed fuel oil. At that time. the NRC did not consider this to be a beyond-scope chance.

,y pm Cooper Nuclear Station improved TS Review Comments ass _c=ues - ITS 3.8.3,. Diesel Fuel Oil, Lube Oil, and Starting Air - 9aa nof' En ' - cHAnifWiN-eedharT gGb3Epd7 RTATIM 2 4 STS 3.8.3 Required Action E.1 This is not a justifiable plant ITS 3.8.3 Required Action E.1 specific or editorial STS Required Action E.1 requires restonng starting air receiver difference. Revise the pressure to 112251 psig. ITS 3.8.3 Required Action E.1 replaces submittal to adopt the STS 2 12251 psig with "within limit." The justification is based on wording. being consistent with the Required Actions of this specification. This is not a plant specific change but is a possible generic change that should be accomplished with a TSTF. NPPD Res >onse: NPPD wiil revise the CNS ITS submittal as suggested in the comment. 3 6 STS 3.8.3 Action E Provide justification for the STS SR 3.8.3.4 STS deviation based on ITS 3.8.3 Action E corrent licensing basis, ITS SR 3.8.3.4 system design, or operational STS 3.8.3 Action E and SR 3.8.3.4 state "... starting air constraints. receiver..." ITS 3.8.3 Action E and SR 3.8.3.4 revises this statement to ".... required starting air receiver..." The justification states that the changes reflect plant specific design and analysis but does not provide any details about actual specific design or analysis. NPPD Response: Only one of the two starting air receivers on each DG is required to support the OPERA 331UTY of the assooated DG. Therprfnre _ NPPD will nrfd a new.lFD tn dier nee thic i m v w -~- .u

s Cooper Nuclear Steelen huysewed TS Reviour Ceaunents m.emamos i y

ITS 3.8.4, DC Soemees - Operedng rr w4 s

.= q.x mm. t ya g-- ~ m:~ m m - ww %c 'm m - g 3.. b ggggggi ~ 111 1' a. Bases discussion of ITS LCO 3.8.4

a. This is not a -

.i Ramme &scussion of ITS 3.8.4 Applicability justdishes plant ; A ~, The ITS Bases replaces the STS words ' antic; pated operational or edstorial difference.= occurrence { ADO)* with " abnormal operational transient.* Note this ' Rwise the subnuttal to ~ is a global difference and should be addressed throughout the ITS. - adopt the STS wording. j naame.

b. Revise all Booss to M

reflect this STS i p .4:- b. , Bares' discussion of Applicable Safety Analysis for ITS 3.8.4 preference. - last sentence - 'c. Adopt the STS word This is a global comment - the last sentence should cite the - since 'specified* doesn't - regulation 10 CFR 50.36(c)(2)(ii) directly, not by referring to add any clarity and ' j p ~ Reference 5. could be confusing in the technical i 13-c.- Bases discussion of ITS 3.8.4 Required Actions B.1 and B.2.- specifications. Note, ~ The ITS Wases uses the word 'specified* in place of the STS word. this comment should be.

required' regarding the time to reach Mode 4 allowed by RG 1.93.

applied globally to all of l the Bases.: i 1 d. Bases discussion of ITS SR 3.8.4.1

d. ' This is not a j

The ITS omits the STS words "(or a battery cell)." justifiable plar.t-specific 'l or editorial difference. i 1, -l .3. e. Bases for ITS SR 3.8.4.8, 3rd paragraph - Revise the Bases to - The ITS Bases replace STS's ibattery rate of deterioration is adopt the ometted ' 'l 3 . increasing" with." battery is getting old and capacity will decrease words. [ more rapidly."

e. This is not a i!

justifiable' plant-specific or editoriel difference.. i Revise the' submittal to ~ adopt the STS wording.

[

b f I -t i b i~ 'i 4 v ,s s -- s ,+.. -.., -.. .~,.c..

.n. ya p b Cooper Nucieer Ste o imoroved TS Review Commwats se. c=uus ITS 3.8.4. DC Sources - Operseing - 3.8.4 - DOC JFD CHANGE /DEFFERENCE COamasafi -STATUS NPPD Response-Co.T.cceu a. The CNS ITS Bases and the CNS USAR ose ' abnormal operational transient

throughout. This is the plant-speofic nornenclature, and NPPD chooses to not revw the submittal as st.sgested.

Comment b. The change, identified in the NRC comment as being incorrect. was incorporated into all of the applicable CNS ITS Bases before the Generic Editorial Change (which proposed the change from *F;nC Policy Statemcw" to *10 CFR 59.36(cH2Hii)*) being submitted to the NRC in its current form. The wording included in the CNS ITS Bases is consistent with that approved by the NRC in the WNP-2 ITS conversion and is more correct than the statements approvert by the NRC in other recently approved ITS conversions. 4 The difference between the word;ng of the Generic Editorial Change and the wording of the CNS ITS Bases (with regard to the reference to 10 CFR 50.36(cH2Hii)) is a matter of presentation preference, is consistent wrth other reference presentation;in NUREG-1433, and has no impact on safety. Therefore, NPPD does not consnier a revision necessary. Comment c. Regulatory Guides do not *requ e* anything, they merely guide interpretation. NPPD c2 moses to use "specified.* Comment d. NPPD will provide more plant-specific justification to maintain the change. _ Comment e. NPPD will revert to the CTS wording. 2 L6 CTS 4.9.A.3.d.3 Revise the submittai ITS SR 3.8.4.8 with a justification for DOC L6 does not address omitting from SR 3.8.4.8 the 17-year in-this omissson. service criteria for requiring a b&ttery discharge test. NPPD Response: The expected battery life at CNS is 20 years. NPPD will add an A DOC discussmg that 17 years is 85% of the expected battery life of 20 years. i

m .d b d Cooper Nucteer Stesion improved TS Review Comments mpmes ITS 3.8.4, DC Sources - Opereeing 2% - 3.8.4 DOC 'JFD CHANGEfDIFFEROWCE m '" CORMAENT STATUS 3 2 STS 3.8.4 Action C Provide juniiswGee for ITS 3.8.4 Actions this STS deviation which STS 3.8.4, required actions for DG DC subsystem, is omitted from describes details of CNS ITS 3.8.4. JFD 2 states these action requirements are not design differences. applecable to the CNS design, but fails to offer details explaining why it is not applicable to the CNS design. NPPD Resmnse: NPPD will revise JFD 2 to st.4e that the CNS design does not include separate DG batteries. 4 L1 3 CTS 3.9.B.3.a ITS J.8.4 Action A This item is referred to - CTS 3.9.B.3.b STS 3.8.4 Action A the PM for tech staff ITS 3.8.4 Action C review. CTS 3.9.B.3.a and CTS 3.9.B.3.b provide Actions, including resto% the inoperable battery within 2 hours or the inoperable battery charger within 4 hours when one 125 V DC or 250 V DC battery or battery charger is inoperable. ITS 3.8.4 Action A ic applicable to only the 125 V DC batteries and associated chargers (subsystems) and ITS 3.8.4 Actio, C. not contained in STS 3.8.4, is separately specif'.ed for the 250 V DC subsystems. Act;on C requires declarir (he associated supported features inoperable - immediately. Arcording to the Bases for ITS 3.8.4 Action C:

a. An inoperable 250 V DC soberstem renders the RCIC system and the Division 1 LPCI subsystem inoperable. The applicable action i

requirements, Action A of ITS 3.5.1 and Action A of ITS 3.5.3 allow 7 days and 14 days, respectively, to restore the RCIC and LPCI subsystems.

b. An inoperable 250 V DC subsystem renders the HPCI system and the Division 2 LPCI subsy: tem inoperable Corresponding Action E of ITS 3.5.1 allow 3 days to restore the HPCI and LPCI subsystems. Increasing the Completion Times from 2 or 4 hours to the times given in ITS Section 3.5 is a significant change and is be end the scope of the conversion.

l r 1 RIPPD Rmenaaem-Nn reennnem ransairert NPPD rnneittore thic r nmment tn he inr intmenal NFlf' feene trzelrina narrmene h

/ f NJ Cooper ph Station Improved TS Review Comments sm_omm ITS 3.8.5, DC Sources - Shutdown 13.8.5-DOC' JFD CHANGE / DIFFERENCE COMMENT ' i STATUS 1 4 STS 3.8.5 SR 3.8.5.1 Revise the submit +al to conform t ITS 3.8.5 SR 3.8.5.1 to the STS wording. STS SR 3.8.5.1 states *For DC sources required to be CFERABLE :.. " ITS SR 3.8.5.1 replaces sources with electrical power subsystems and states "For DC electrical l power subsystems required to be OPERABLE, _. The justification is based on being consistent with the wording of the LCO and ACTION. This is not a plant specific change but is a possible generic change to the STS that should be accomplished using the STS generic change process. NPPD Res xmse: NPPD will revise the CNS ITS submittal according to the comment. l 2 5 STS SR 3.8.5.1 Revise the submittal to conform ITS SR 3.8.5.1 to the STS wording. l STS SR 3.8.5.1 lists the SRs to be performed in a column format. ITS SR 3.8.5.1 lists the same SRs in a sentence format. The just'ification is based on being consistent with i the Writers Guide. This is not a plant specific change but is a possible generic change to the STS that should be accomplished using the STS generic change process. g I NPPD Response: NPPD will revise the CI,5 ITS submittal according to the comment. i I h l

p) (- x) %J Cooper Nucteer Station improved TS Review Comments m_c== ITS 3.8.5, DC Sources - Shutdown 7 C'iA. 8GE/DIFFiRENCE CommAENT STATUS J3.8.5 DOC JFD - r -3 ITS 3.8.5 Actions Note and asi,06ated Bases This note is not necessary. discusson Explain how there could be an . TSTF-36

inability to suspend movement of irradiated fuel assemblies
for ITS 3.8.5 adds a note to the Actions of STS 3.8.5 stating
up to 6 hours.* Withdraw it LCO I ' % not applicable." The justification is based on from the submittal.

information in TSTF-3S. The disposition of TSTF-36 R 1 and R.2 is ~Pending.* NPPD Response: The proposed Note to the ITS 3.8.2 ACTIONS provides a necessary clarification, because defaulting to ITS LCO 3.0.3 (during irradiated fuel assembly movement in MODE 1,2 or 31 would require the reactor shut down, but would not require immediate suspension of movement of irradiated fuel assemblies when required components are inoperable. ITS LCO 3.03 is only applicable in MODE 1,2 or 3. Therefore, once the unit is in MODE 4 in accordance with ITS LCO 3.0.3. ITS LCO 3.0.3 is no longer applicable. The actions of the " shutdown

Electrical Power System Technical Specifications (i.e ITS 3.8.2 ACTIONS), which require susperupon of irradiated fue! movement, would then be applicable. How.tver, the requirements of ITS LCO 3.03 would allow up to 37 hours to place the unit in MODE 4 (and as a result up to 37 hours would be allowed to suspend irradiated fuel movement). Therefore, with the unit in this Condition, the Note, "LCO 3.0.3 is not applicable,* ensures that the actions for requiring immediate suspension of movement of irradiated fuel assemblies are not postponed due to entry into ITS LCO 3.0.3 and that the unit is immediately placed in a coexfition of menemum risk, with respect.to fuel handling activities during MODE 1, 2 or 3. A revision to generic change Technical Specification Task Force (TSTF)-36 hae hasn nrnnneed in rebet this infnrmatinn L

.C ((O O f V Cooper Mh Station improved TS Rawiew Comments see.omosas ITS 3.8.6, Bettery Ces Parameters '3.8.6 DOC- <JFD CHAIGGE/ DIFFER 90CE C OtmAEN T STATUS 1 CTS Table 3.9-1 footnote (5) ITS Table 3.8.6.1 footnote (b) Prowde discussion and ju.ti& tion for the CTS CTS Table 3.9-1 footnote (5) requires correcting specific granty change stating that level for electrolyte temperature and level. ITS

bie 3.8.6.1 correction is not requred i

footnote (b) has the same requirement but also states that when on float charge and level correction is not required when on float charge and bettery cN v;.,g current is battery charging current is < 2 amps. No discust. ion or < 2 amps. justification is provided for this change to the CTS. NPPD Response: NPPD wiH add an L DOC to address not requiring level correction of specific gravity when on float charge and when battery charging current is less than 2 amps. 2 3 STS 3.8.6 Condition B ITS 3.8.6 Condition B These are not plant specific STS Table 3.8.6.1 Category C ITS Table 3.8.6.1 Category C differences. Revise the submittal to adopt the STS

a. The (Wd Condition of STS Condition B states

parameters wording.

not within Category C values.* ITS 3.8.6 Condition B replaces the word

values
with
limits". The justification is to more NPPD is encouraged to closely match the LCO description.

initiate a generic change

b. The STS Table 3.8.6.1 Category C column is entitled proposal to the idiF.

Category C: Allowable Limits for Each Connected Cell."

iTS Table 3.8.6.1 deletes the word " Allowable.* The justification is to be consistent with manner in which Category C *Lirruts* are described in the Actions and that is wi!I avoid confusion with the term " Allowable Value' used in the Instrumentation section. These are not plant specific :hanges but are possible generic changes that should be accomplished using the STS gecenc change process. NPPD Response: NPPD will develop a cenaric change to the STS. i - ~ _~

+ s (% J c ,.c mes r se eien n.u Ts n i c fis 3.s.s, estiary ces Par eers o STATU - 3,g g - DOC D- 'CHA80C.GDW:FBtBUCE ~ CORAEffTs _ 3 2-ITS LCO 3.8.6 ITS SR 3.8.6.3 This drfference is acces:tatde: thus the STS should be Unike the STS, the ITS specificaNy requires electrolyte corrected. NPPD is - temperature to be within Iwnits (given in SR 3.8.6.3) because encouraged to ine.ee a ITS Table 3.8.6-1 does not specrfy electrolyte temperature limrts. gewric ch.nge proposal to This is a generic difference from the STS. the TSTF. .,,W-6 U b D REna a m b b 4k [ y I f I I i l t 1 6 i i 4 i. I

y O O O Cooper Nuclear Station improved TS Review Comments m.c== ITS 3.8.7, Distribution Systems - Operating Q.8.7 DOC- ~JFD CHANGE / DIFFERENCE COMNG8T STATUS 1 4 STS t.CO 3.8.9 STS SR 3.8.9.1 Revise the submittal to STS 3.8.9 Action B ITS LCO 3.8.7 expliotly conf ~ m w STS 3.8.9 Action E ITS 3.8.7 Actions whether or not CNS has ITS Beces Table 8 3.8.7-1 AC vital buses or a DG DC electrical power The STS LCO 3.8.9 and SR 3.8.9.1 include the AC vital bus and distrtution system. Action B contains Conditions and Required Actions for the AC vital bus. These are not included in corresponding ITS 3.8.7. In addition in addition. the smooth ITS 3.8.7 does not include STS Action E for the DG DC electrical versson of the Bases power distribution system. The justificatiore for these STS changes is table is incorrectly that the bracketed items are not applicable to CNS. This implies that labeled B 3.8.9-1:it CNS does not have a vital AC bus or a DG DC electrical power should be B 3.8.7-1. distribution system. However this is t'ot specifically stated in either the justification for the deviation or in the Bases discussion. NPPD Response: NPPD will revise JFD 4 with supporting plant-specific detail and will correct the typed ITS Bases Table as identified in the comment. 2 1 STS 3.8.7 and 3.8.8 Revise the submittal to explicit!y confirm STS 3.8.7 and STS 3.8.8 contain requirements for inverters r hen whether or not CNS has operating and when shutdown, respectively. The ITS does not inverters or comparable implem2nt these requirements. The justification states that these STS equipment, such as MG sections are deleted because they are not applicable to CNS. Although sets. not explicitly stated in either the justification or the Bases, this implies that CNS does not have inverters. In addition there is no discussion of how the function of supplying AC power that is derived from DC (such as by using inverters or MG set (s) is provided. NPPD Response: CNS does not have inverters like those addressed in the ISTS. At CNS, MG sets supply AC power derived from DC. (ITS 3.3.8.2 talks about these MG sets.) NPPD will update JFD 1 for ISTS 3.8.7 and ISTS 3.8.8 with this information.

, ~. ( ) G) v C-::;;: ph Station improved TS Review Comments m_c=ues ITS 3.8.7 Distritmstion Systems - Opereeing ' 3.8.7 ~- DOC JFD ' CHANGE / DIFFERENCE COMMENT STATUS . 3. ' A.4 ' 5 CTS 3.9.A.1.d This item is referred to CTS 3.9.B.3.a the PM for tech staff CTS 3.9.B.3.b review. STS 3.8.9 ITS 3.8.7 Act' n D e ITS 3.8.7 Action D is included to require that supported subsystems (including LPCI, RCIC, and HPCI subsystems) be declared inoperable immediately upon discovery that a 250 V DC distribution subsystem is inoperable. As discussed in Comment 3.8.4-4, in terms of when a l shutdown is required, this changes relaxes this time from 2 or 4 hours g to 3 or 7 days, depending upon the division that is inoperable. This is 4 a significant change and is beyond the scope of the conversion. NPPD Response: No response required. NPPD considers this comment to be for intemal NRC issue tracking purposes. 8 i I t l l I I

V (). Cooper Nuclear Station improved TS Review Comments m.cmases ITS 3.8.7. Distribution Systems - Operating 3.8.7-- ' DOC-JFD CHANGE /DIFFEROWCE COMMENT ' STATUS 4 5 ITS LCO 3.8.7 Revise the submittal ITS 3.8.7 Actions to conform to the STS ITS Bases Table 3.8.741 presentations of Bases discussion of ITS LCO 3.8.7 S3 markup insert 1 requirements - a complete list of The Bases for the simplified Actions table in STS 3.8.9 is that all electrical busses and safety related electrical busses, motor control centers, panels, etc. panels in the Basas would be listed in the Bases table, relieving the operator from declaring table. inoperable numerous components supplied by one of these busses or panels. For simplicity, a common time of 8 hours was established for Note that the ITS for AC distribution subsystems and 2 hours for DC distribution Hatet.1 and 2 were subsystems, and 2 hours for Vital AC subsystems - regardless of the approved with no Bases importance of the systems supported by these distribution table, but with a fairly subsystems. By not listing in the Bases table all panels supplying comprehensive listing safety-related loads, the ITS conflicts with the rational behind the STS of electrical busses and Actions table. NPPD proposes to mix cascading, no-cascading, and panels in the LCO itself. j Action-directed cascading in the ITS 3.8.7 Actions table. The STS See the Hatch SE page tries to avoid such an arrangement. The CTS requirements for 278. Such a distribution systems are only covered by the definition of operability - presentation may be which implies that anytime a panel or bus is discovered inoperable, acceptable for CNS. all supported loads should be declared inoperable and appropriate TS l' action requirements should be met,i.e., complete cascading. The STS approach - no cascading - was concluded to be an improvement. The 250 V DC busses may be a special case because of the relatively few safety related rubsystems they support. Thus, ITS Action D, which directs cascading to the ECCS and RCIC specifications, may be l an acceptable difference from the STS. Its acceptance is onen pending resolution of Comments 3.8.4-4 and 3.8.7-3. NPPD Response: NPPD will change the NCS ITS submittal to include the approach used by Hatch, as suggested in the comment j (but with oniv the listino of bn==== currentiv orovided in ITS R==== T=ht B 3.8.7-13

f w) w/ Cooper Nuclear Station improved TS Review Comments we.c=sms ITS 3.8.8, Distribution Systems - Shutdown 3.8.8 ~ DOC 'JFD CHANGE /DfFFERENCE COMMENT STATUS 1 2 STS LCO 3.8.10 Revise the submittal to STS 3.8.10 Condition A and Required Actica A.2.4 explicitly confirm whether or STS SR 3.8.10.1 not CNS has AC vital buses. ITS LCO 3.8.8 See Co.T T.ent 3.8.7-1. ITS 3.8.8 Condition A and Required Action A.2.4 ITS SR 3.8.10.1 The STS 3.8.10 LCO, Condition A. Required Action A.2.4 and SR 3.8.10.1 includes requirements, Conditions, and Required Actions for the AC vital bus. These are not included in the entresponding ITS 3.8.8. The justification for these STS changes is that the plant specific value/ nomenclature has been provided for the bracketed items. This implies that CNS does not have a vital AC bus. However this is not specifically stated in either the justification for the deviation or in the Bases discussion. NPPD hessonse: NPPD will revise JFD 2 with supporting plant-specific detail. 2 STS 3.8.10 ACTIONS See Comments 3.8.2-2 and ITS 3.8.8 ACTIONS 3.8.5-3. ITS 3.6.8 contains a note to the ACTIONS not found in STS 3.8.10 stating LCO 3.0.3 is not applicable." The justification is based on information in TSTF-36. l NPPD Response: The clarification the proposed Note provides to the ITS 3.8.8 ACTIONS is necessary because defaulting to ITS LCO 3.0.3 (during irradiated fuel assemtly movement in MODE 1,2, or 3) would require the reactor shut down, but would not require immediate suspension of movement of irradiated fuel assemblies when required components are inoperable. ITS LCO 3.0.3 is only applicable in MODE 1,2, or 3. Therefore, once the unit is in MODE 4 in accordance with ITS LCO 3.0.3, ITS LCO 3.0.3 is no longer applicable. The acFons of the " shutdown" Electrical Power System Technical Specifications (e.g., ITS 3.8.8 ACTIONS), which require suspension of irradinted fuel movement, would then be applicable. However, the requirements of ITS LCO 3.0.3 would allow up to 37 hours to place the unit in MODE 4 (and, as a result, up to 37 hours attowed to suspend irradiated fuel movement). Therefore, with t'w unit in this Condition, the Note, "LCO 3.0.3 is not applicable,* ensures no postponement of the actions for requiring immediate suspension cf movement of irradiated fuel assemblies due to entry into ITS LCO 3.0.3 as well as immediate placement of the unit in a condition of minimum risk, with respect to fuel handling activities dur;ng MODE 1,2, or 3. A revision to generic change Technical Specification Task Fnree fTMTF1afi has been nrnnnterf in ref1 pet this infnrmatinn .}}

ML20197E777

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