ML20202H527
| ML20202H527 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/09/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS980029, TAC-M98317, NUDOCS 9802200408 | |
| Download: ML20202H527 (33) | |
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NLS980029 February 9,1998 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Second Ree !est for Additional Information Regarding the improved Technical c
SpeciScations Cooper Nuclear Station, fiRC Docket 50-298, DPR-46
Reference:
- 1. Letter from G. R. llorn (Nebraska Public Power District ) to US Nuclear Regulatory Commission dated March 27,1997, " Proposed Change to CNS Technical Specifications, Conversion to impioved Standard Technical Specifications"
- 2. US Nuclear Regulatory Commission Letter from J. R. Hall to G. R Ilorn dated December 22,1997,"Second Request for AdditiorialInformation Regarding the improved Technical Speci6 cations (TAC No. M98317)"
13y 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 fonvarded a second request for additionalinformation (RAl) regarding this proposed change. In response to the RAl, the District is providing, as an Attachment, its response to each of the individual NRC questions.
Should you have any questions concerning this matter, please contact me.
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NLS980029 February 9,1998 Page 2 of 2 cc: Regional Administrator w/o attachment USNRC - Region IV Senior Project Manager w/ attachment USNRC - NRR Project Directorrae IV-1 l
Senior Resident inspector w/o attachment USNRC NPO Distribution w/o attachment
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS j
Correspondenca Nos_NLS900029 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 t? 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 in accordance with the N/A responses to each of the individual questions.
1 l
l PROCEDURE NUMBER 0.42 l
REVISION NUMBER S l
PAGE 9 OF 13 l
No Action degligible Minor Moderate Major Required impact' impact Impact' impact' 2
- l. 3.3.1.1-3 3.3.1.1-1 3.3.2.1-2 3.3.1.1-2 i
2-3.3.2.1 1 3.3.1.1-5 & -6 3.3.5.1-2 3.3.1.14 3 3.3.2.2-1 3.3.2.1-3 3.3.2.2-2 4-3.3.3.1-1 3.3.5.1-1 3.3.4.1-1 5-3.3.3.1-2 3.3.5.1-4 6-3.3.3.2-1 3.3.5.2-1 73.3.5.1-3 3.3.6.1.I 8-3.3.5.1-5 3.3.6.22 9-3.3.5.1-6 3.3.6.2-5 10 3.3.5.2-2 3.3.6.3-1 1 l-3.3.6.1-2 3.1.7.1 '
I2-3.3.6.1-3 3.3.8.14 13-3.3.6.2-1 3.3.8.2.I 14 3.3.6.23 15-3.3.6.2-4 I 6-3.3.8.1-2 I 7-3.3.8.2-2 i
liighest Potential Imnact l-Change DOC, NSilC, and/or JFD 2-Change Submittal-Ilases 3-Change Submittal - LCO and Ilases 4-Change Submittal-LCO and Dases l
Cooper Nuclear Sta6on improved TS Review Comments un_oaves ITS 3.3.1, RPS Irm 3.3.1.1 DOC JFD CHANGE /CIFFERENCE CORAGENT STATUS 1
L3 CTS Table 3.1.1 Note A Provide discussions of change for ITS Table 3.3.1.1-1 Functions Ia,1b,7,10, c.nd 11 changes, that have not been ITS 3.3.1.1 Action H addressed, to CTS required Achons forthe RPS Funchons Discussion of Change L3 addresses the MODE 5 Action affected by the change from change for the Scram Discharge Volume High Water Level, CTS Table 3.1.1 Note A to the RPS Function 7. The same Action change from CTS Table wiisi+006,ng ITS 3.3.1.1 3.1.1 Note A to ITS 3.3.1.1 Action H applies to ITS Table Action H requirements.
3.3.1.1-1 Function Ia, IRM Neutron Flux - High, Function 1b, IRM inop, Function 10, Reactor Mode Switch - Shutdown Position, and Function 11, Manual Scram, in MODE 5.
However, no discussion orjustification for the three similar changes are included in the submittal.
NPPD Response: In a revision to the Cooper Nuclear Station (CNS) Improved Technical Specifications (ITS) submittal. Nebraska Public Power District (NPPD) will revise the Discussion of Change (DOC) L3 for ITS 3.3.1.1 to include the IRM Neutron Flux-Hegh Function, IRM inop Function, Reactor Mode Switch-Shutdown Position Function, and Manual Scram Function. This revision will make DOC L3 for ITS 3.3.1.1 consistent with the Current Technical Specifications (CTS) markup pages.
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Cooper Nuclear Station improved TS Review Comments sm_oe =3 ITS 3.3.1 RPS Instrumentation 0
3.3.1.1 00C l JFD CHANGEIDIFFERENCE COMMENT STATUS 2
LAV CTS 2.1.A Fuel Cladding IntegntyTrip Settings Acceptability of the changed CTS 2.2 Reactor Coolant System Integrity Trip setpoints/ allowable values is Settings contingent upon the NRC CTS Table 3.1.1 RPS lastrumentation Requirements determining acceptable the ITS Taole 3.3.1.1-1 Functions ia,2a,2b. 2c,2d,3,4, apphcation of the GE Setpoint 6,7 and 9 Methodology documented in NEDC-31336.
The CTS trip setting values for many RPS Functions are changed in ITS Table 3.3.1.1-1 to reflect new Allowable Value based on the CNS Setpoint Methodology Proyain.
Justification provided indicates that the new values are established consistent with the GE Setpoint Methodvicgy.
The following CTS RPS Function Limiting Safety System 1
Settings listed in CTS Table 3.1.1 are changed in ITS Table 3.3.1.1-1, by ITS Table 3.3.1.1-1 Function number:
1a,2a,2b,2c,2d,3,4,6,7,9.
4 NPPD Response: No response required. NPPD considers this cuninrent to be for intemal NRC issue tracking purposes.
The setpoint calculation issues previously identified in letter NLS97G124 from NPPD to Le NRC are being addressed by a fully independent review of the calculations. Based on the results of the independent review, the < point calculations will be revised, as needed, and approved.
NPPD expects the review and setpoint calculation markup activities to be completed no later than Man:h 31,1998. NPPD will revise the ITS submittal, as needed, to reflect the results of these activities.
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Cooper Nuclear Station improved TS Review Comments
1 STS Table 3.3.1.1-1 Verify that these RPS Funchons ITS Table 3.3.1.1-1 have no control room displays that can be monitored every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Channel Checks required in STS Table 3.4.1.1-1 forthe for a compenson between Reactor Pressure - High, Drywell Pressure - High, and Scram channels (Channel Check).
Discharge Volume Water Level-High Functions are deleted in ITS 3.3.1.1-1. JFD 1 justifies the deletion with the fact that these RPS Functions cannot be monitofed because they are switches only. Reactnr Pressure - High is a PAM Function required Operable by ITS 3.3.1.1. It is not clear that thesa RPS Functions have no control room displays.
NPPD Response: The Reactor Protection System (PPS) Functions for Reactor Pressure +1igh, Drywell Pressur@, and Scram Discharge Volume Water Level-High have no dispisys that can be monitored in the control room for the peihriisice of E CHANNEL CHECK. None of these trip channels has any indication function, and the PnM functions with the same names are driven by different instruments.
4 5
The frequency for conducting the ITS SR 3.3.1.1.7, on What frequency do current Channel Flow Signal Adjustment, has been changed from 7 procedures require the days in the STS to 31 days in the ITS, based upon plant performance of this SR7 operating experience (and CLB).
NPPD Response: Since CNS does not perform this surveillance under the current licensing basis, there are no plant procedures that cover this added requirement. Therefore, NPPD will revise the CNS ITS submittal to accept the STS 7-day Frequency for ITS SR 3.3.1.1.7.
NPPD chooses to keep the numbering of this SR as ITS SR 3.3.1.1.7 to avoed the negative impact the change eld have on work in pivviess.
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Cooper Nuclear Station improved TS Review Comments
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ITS 3.3.1, RPS instumentation 3.3.1.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 5
A9 The Scensee's A.9 DOC states: CTS Table 3.1.1 provides an The CTS also requires option of either inserting all Operable rods within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> depressurization to <1000 psig.
(being in MODE 3) or reducing poww *o the IRM range and Does the safety analysis no longer placing the reactor mode selector swnch in startup (being in require this depressurization? The MODE 2) if the MSIV-Closure Function nas less than the elimination of this requirement minimum number of Operable channels per trip system.
makes this a less restrictive Proposed ACTION F requires only entry into MODE 2. The change.
MSIV-Closure Function is only required in MODE 1 since, with the MSIVs open and the heat generation rate high, a r
pressurization transient can occur if the MSIVs close. In MODE 2, the heat generation rate is low enough so that the other diverse RPS functions provide sufficient protection.
Therefore, once the plant reaches MODE 2, the LCO is no longer applicable. The CTS option of proceeding to MODE 3 is unnecessary; therefore, this change is considered administrativa.
NPPD Response: The Applicability of the RPS Main Steam isolation Valve (MSlV)-Closure Function, in both the CTS and the ITS, is MODE 1 (i.e., reactor mode switch in run). As a result, placing the unit in MODE 2 results in exiting the Appik;.bility of the LCO for this Function and 3
there is no need to require further actions to be performed (Le., reactor depressurization to < 1000 psig) in scirndern.6 with ITS LCO 3.0.2.
In addition, the safety analysis for overpressurization dnes not assume the MSIV-Closure Function (direct scram on position switches).
Therefore, there is no safety analysis basis for the CTS requirement to depressurize the reactor to < 1000 psig in the event the MSIV-Closure Function is inoperable. In a revision to the CNS ITS submittal NPPD will revise DOC L7 for ITS 3.3.1.1 to provide this additional informabon.
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Cooper Nuclear Station improved TS Review Comments am_oem ITS 3.3.2.1, Control Rod Block Instrumentation 3.3.2.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1
LA2 2
CTS Table 3.2.C This change to CTS ITS Table 3.3.2.1-1, Functions 1a,1b, and 1c requirements results in a deviation from the STS.
The trip level settings specified in CTS Table 3.2.C for the Rod Block Provide justificaben for not Monitor Upscale trip are moved to the COLR. STS Table 3.3.2.1-1 including the Allowable includes Allowable Values for these functions; the ITS table refers to Values in the ITS.
the COLR. This CTS change results in a deviation from the STS and justification is not provided.
NPPD Response: The Allowable Values for the Rod Block Monitor Upscale Functions vary based on MCPR limits. MCPR frnits are cycle dependent and are already included in the Core Operating Limits Report (COLR) in accordance with Genenc Letter 88-16. Therefore, the Allowable Values for the Rod Block Monitor Upscale Functions may also be cycle dependent and are proposed to be relocated to the COLR.
Relocation of these Allowable Values to the COLR is acceptable since iTS Tabla 3.3.2.1-1 states that the Allowable Values shall be as specifkxi j
in the COLR and programmatic requirements for the COLR are included in ITS Section 5.6. The COLR requirements, in ITS Section 5.6, specify l
the scope of the limits in the COLR and mandates NRC approval of the analytical methods used to develop the limits in the COLR.
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2 LA1
'US Table 3.2.C AII of the details to be
- 4. S 3.3.2.1 relocated to the Bases do not appearthere. Include System design and operational details contained in CTS Table 3.2.C details in the Bases.
(Notes 5,10c,14 & 16) are to be relocated to the Bases. The details are not necessary to ensure that the Control Fiod Block Instrumentation is Operable and are necessary to be in the ITS.
NPPD Response: The markups for LCO 3.3.2.1 include the information insert 1 of the NUREG-1433 (ISTS) Bases provides for CTS Table 3.2.C Notes 5,10c, and 16. In a revision te the CNS ITS submittal, NPPD will include the information in CTS Table 3.2.C Note 14 in the Bases for ITS 3.3.2.1.
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Cooper Nuclear Station improved TS Review Comments m,pe,e ITS 3.3.2.1, Control Rod Block instrumentation 1
3.3.2.1 DOC JFD CHANGE / DIFFERENCE ColeMENT STATUS 3
L3 CTS 3.3E3.c Provide a more accurata ITS 3.3.2.1 discussion conceming why the changed required With an inoperable RWM and with a lack of sppropr'ste monitoring of actions are Less CR moverrent, the required action has been relaxed from *immediate Restnctive and why they shutdown" to an attemative that 'mcludes the cessation of CR are acceptable.
movement. The DOC inaccurately describes the new required actions as being "more conservative."
NPPD Response: The RWM is a monitoring system that ensures the reactor operator adh( ss to a predetermmed sequence for control rod withdrawal Bad insertion to enforce the banked position withdrawal sequence (BPWS). This unsures that the initial conditions of the control rod drop sc.Ght (CRDA) are met. Prohibiting control rod movement when the RWM is inoperable and appropnete monstonng in not in c.ffect, in conditions when BPWS requirements are met, may be considered a conservative appc-cli. This is insteed of bnngmg the reactor to "a shutdown condition imreediately
- The requirements of LCO 3.1.6
- Rod Pattem Control," will ensure that adequate cci6pensatory measures are taken when the BPWS requirements are not met. In addition, the immediate shutdown action of the CTS requires insertion of all control rods. This action could possibly put the reactor into an undesirable shutdown transient condition. In a revision to the CNS ITS submittal, NPPD will revise DOC L3 for ITS 3.3.2.1 to address tais.
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Cooper Nuclear Station improved TS Review Comments ITS 3.3.2.2, Feedwater and Main Turtune High Water Level Trip Instrumentation 3.3.2.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1
2 CTS Table 4.2.J Adopt STS SR 3.3.2.2.
The ITS does not include STS SR 3.3.2.2.2 CHANNEL FUNCTIONAL TEST (CFTi at a 92 day frequency, because it is not in the CTS. This means the CFT is acc,iripiished at 18 months, when the CHANNEL CALIBRATION is performed. The CFT frequency is based upon reliability data in topical report GENE-770-06-1, ths same topical used to justify adding the note permitting a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> delay in entering the LCO required actions when performing SRs.
l NPPD Response: The requirements for Feedwater and Main Turbine Trip High Water Level Instrumentshon were added to the CTS in Amendment 169, dated June 8,1995. The NRC Safety Evaluation for this Amendment said the NRC position on the acceptabihty of the existing functional test frequency for this instrumentation (i.e. once per operating cycle) was "no impact on plant safety.... Therefore,... is acceptable.* Therefore, based on the current licensing basis reflected in CTS Table 4.2.J. NPPD does not choose to adopt the ISTS 92 day Frequency for performance of the CHANNEL FUNCTIONAL TEST of this instrumentation.
2 LAV CTS Table 3.2.J Acceptability of the changed ITS SR 3.3.2.2.3 setpoints/ allowable values is ccieiigant upon the NRC The CTS Table 3.2.J setting limits for the Feedwater and Main Turbine determining acceptable High Water Level Trip Instrumentation is changed in ITS SR 3.3.2.2.3 apphcation of the GE to reflect a new Allowable Value based on the CNS Setpoint Setpoint."?,:iicdeicgy Methodology Program. Justification provided indicates that the new documented in values are established ;:onsistent with the GE Setpoint Methodology.
NPPD Response: No response regaired. NPPD considers this comment to be for intemal NRC issue traciong purposes. See the added l
response to item Number 3.3.1.1-2.
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Cooper Nuclear Station improved TS Review Comments ITS 3.3.3.1, Post Accident Monitoring (Pam) instrumentation 3.3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1
9 ITS 3.3.3.1 Actions Note Adopt the STS 3.3.3.1 Actions STS 3.3.3.1 Actions requirements (delete Function ITS 3.6.1.3 Actions 5 note on separate condition entry), or initiate a generic A note is added to the ITS 3.3.3.1 PAM instrumentation Actions for change packaga.
Function 5, PCIV Position, which allows separate Condition entry for each penetration flow path. This allowance is not included in STS 3.3.3.1. There is no plant specific design jus,tif' ation for the added c
allowarce. However, the added allowance makes the instrumentation LCO Actions consistent with tlae LCO 3.6.1.3 Actions for the Primary Containment isolation Valves.
NPPD Response: A generic char.ge package has been processed through the NEl Technical Specircation Task Force for this change.
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2 STS 3.3.3.1 Required Action D Adopt the STS ACTION D and ITS 3.3.3.1 the associated NOTE in CTS Table 3.2.H ACTION C.
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STS ACTION D and the NOTE in ACTION C have been deleted in the ITS. Where STS ACTION D specifies a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time (CT) to restore one hydrogen monitor when two are inoperable, the ITS allows a 7 day CT. This deviation is based upon current licensing basis and the statement that the hydrogen monitor functions are no less important than the oxygen monitor function.
The STS CT is specifically shorter for the hydrogen monitor function due to its safety signifcance.
NPPD Response: The 7-day Completion Time for restoration of one inoperable hydrogen monitor, when two hydrogen monitors are i.wbie, is based on the current licensing basis reflected in CTS Table 3.2.H and Note B.2 to Table 3.2.H. NPPD does not choose to adopt the ISTS 3.3.3.1 Required Action D.1 Completion Time, and assocated Note to ISTS 3.3.3.1 Condition C, for this Condition.
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4 Cooper Nuclear Station improved TS Review Comments a cus e,
ITS 37.3.2, Alternate Shutdown System 3.3.3.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1
LA1 2
CTS Table 3.2.1-1 This change does not maintain CTS Table 3.2.1-2 the current licensing basis and CTS Table 4.2.1 also results in a deviation from STS Table 3.3.3.2-1 the STS. Therefore, the change is outside the scope of The Altemate Shutdown Instrumentation requirement listings in the conversion.
CTS Tables 3.2.1-1&2 and surveillance requirement listings in CTS Table 4.2.1 are not maintained in ITS 3.3.3.2. The STS Table 3.3.3.2-1 format and listing of these requirements is not adopted. Instead, the information is listed in the ITS Bases.
NPPD Response: The relocation of the A! ternate Shutdown System instrument listings to the Bases is consistent with the guidance in Generic Letter 91-08 for the removal of lists from the Technical Specifications. This change may be beyond the scope of the NRC Technical l
Specification Branch review; however, the NRC has previously approved the relocation of this information from the Technical Specifications to
(
the Bases as part of other BWR ITS conversions (Beach Bottom and WNP2, for example).
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Cooper Nuolear Station improved TS Review Comments ITS 3.3.4.1, Anticipated Transient Without Scram Reoirculation Pump Trip instrumentation 4
3.3.4.1 ' ' DOC JFD CHANGE / DIFFERENCE COGNWIENT STATUS 1
LAV CNS Table 3.2.G Setting Limits Acceptability of the changed ITS SR 3.3.4.1.2 Allowsole Values setpoints/ allowable values is contingent upon the NRC The CTS Table 3.2.G Setting Limits for the ATWS-RPT Functions determtning acceptable are changed in 'TS SR 3.3.4.1.2 reflecting new Allowable Values application of the GE Setpoint l
based on the CNS Setpoint Methodology Progiani. Jushfication Methodology documented in i
provided indicates that the new values are established consistent NEDC-31336.
with the GE Setpoint Methodology.
NPPD Response: No response required. NPPD consulers this coininent to be for intemal NRC issue tracking purposes. See the added response to item Number 3.3.1.1-2.
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Cooper Nuciear Sta6on improved TS Review Comments m_o==s ITS 3.3.5.1, Emergency Core Cooling System (ECCS) instrumentation i
3.3.5.1 DOC JFD CHANGEIDIFFERENCE COMAENT STATUS 1
L6 CTS Table 3.2.B Provide descussion and CTS Table 4.2.B Justification for the deleted ITS Table 3.3.5.1-1 trip function associated with the Control Oil Pressure-The HPCI Control Oil Pressure - Low Functior included in CTS Table Low Funchon.
3.2.B and Table 4.2.8 is deleted on the basis that it is an indication-only Function. However, the CTS Function includes a Setting Linnt, which indicates a trip function. The discussion of change does not address any trip function, only a rnonitoring function.
NPPD Response: In a revision to the CNS ITS subnuttal, NPPD will reviss DOC L8 for ITS 3.3.5.1 to provide additional justificahon for the deletion of the Technical Specification requirements for the HPCI Control Oil Pressure-Low Function.
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Cooper Nuclear Station improved TS Review Comments m,paus ITS 3.3.5.1, Emergency Core Cooling System (ECCS) instrumentation 3.3.5.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 2
1.A2 CTS Tables 4.2.A through 4.2.F Note 4 Provide additional ITS 3.3.5.1 Bases discussion and justification, explaining how the Logic CTS Tables 4.2.A-F Note 4 requires Logic System Functional Tests to System Functional Test is be performed by simulated automatic actuation. The discussion of performed to demonstrate change indicates that this detail is moved to the iTS SR 3.3.5.1.5 the safety function without Bases. The ITS SR 3.3.5.1.5 Bases does not provide this detail.
the deleted detait NPPD Response: In a revision to the CNS ITS bmittal, NPPD will revise the Bases for ITS SR 3.3.5.1.5 to include the information about performing the LOGIC SYSTEM FUNCTIONAL I JT (i.e., by " simulated automatic actuation").
CTS 4.2.B. Table 4.2.B. and Note 4 to Table 4.2.8 require penodic performance of " system logic tenctional tests" and " simulated automatic actuation." The requirement for " simulated automatic actuation"is a detail of the method for performbg LOGIC SYSTEM FUNCTIONAL TESTS.
The CTS does not include a definition of " system logic functional tests" and, therefore, does not include the details of the method of performing a LOGIC SYSTEM FUNCTIONAL TEST, which are inhere. t in the ITS definition. The ITS definition exphcitly states that the entire logic system is tested. Performing the LOGir SYSTEM FUNCTIONAL TEST and satisfying the requirements of the ITS definition without a real actuation requires simulated automatic actuation of the channels. Therefore, the additional CTS requirement for " simulated automatic actuation"is not required inclusion in the Technical Specifications to ensure performance of the required testing.
Cooper Nuolear Station improved TS Review Comments assip.ve.
ITS 3.3.5.1, Emergency Core Cooling System (ECCS) instrumentation 3.3.8.1 DOC JFD CHANGE / DIFFERENCE NEWT STATUS 3
7 STS Tablo 3.3.5.1-1, Functions 1e,2h,3g,4h, and Sh include the Massed initianon ITS Table 3.3.5.1-1. Functions 1e,2h,3g,4h, and Sh Functions in the ITS, STS 3.3.5.1 Bases consistent with the STS and Bases. Or, provide system STS Table 3.3.5.1-1 ECCS ManualInitiation Functions 1e,2h,3g,4h, design sp c.iik. justification and Sh for CS, LPCI, HPCI, and ADS are deleted from ITS Table for not adopting the STS 3.3.5.1-1. The Justification For Deviation #7 justifies this omission of and associated Bases.
STS requirements based on current licensing basis, and the fact that these Manual Initiation Funcbons are not credited in the safety analysis.
However, the STS 3.3.5.1 Bases for these Functions states that these Functions are not typically assumed in any accident or transient analyses in the FSAR. And, that the Function is retained in the TS for overall redundancy and diverssty of the associated ECCS Functions as required by the NRC in the plant licensing basis.
NPPD Response: The CNS design does not include the pushbutton manual actuation instrumentshon funchons desenbod in the ISTS Bases for LCO 3.3.5.1 for Core Spray. Low Pressure Coolant injection, High Pressure Coolant Irijection, or the Automatic Depressurization System. NPPD made the change to the ISTS to refiect the plant-specific design.
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1 Cooper Nuoleer Staton improved TS Review Comments i
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ITS 3.3.s.1, Emergoney Com CooEng System (ECCSHnskumentaton 3.3.4.1 DOC JFD CHANGWDIFFERENCE CORASENT STATUS j
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Arraf*=hany of the changed CTS Table 3.2.8 Setting Limits setpoints or au ITS Table 3.3.5.1-1 Alloweble Values values is contingent upon the NRC determining r
The CTS trip setting limits for the ECCS inihetion Funchons in CTS arc =ptable applicehon of i
Table 3.2.B are changed in ITS Table 3.3.5.1-1 to reRect new /Joweble the GE Satpoint Values based on the CNS Setpoent Methodology Picy m.
Wion Methcdology documented in l
provided indicates that the new values are established consistent with NEDC-31336.
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the GE Setpoint Methodology.
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j NPPD Response: No response required. NPPD esiders this comment to be for intemel NRC issue tracking purposes. See the added l
response to item Number 3.3.1.1-2.
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- A3 These CTS Tables 3.2.B and 4.2.B Funchons related to low voltage on The informehon proposed to an individual bus / component are proposed to be moved to SpeciReshon be moved to 3.8.1 does isot i
j 3.8.1 in accordance with the format of the BWR Standard Technical appoorin eitherTS or
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Specifications, NUREG-1433 Revision 1. Any technical changes to Bases.
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i-these Functions will be addressed in the Discussion of Changes for ITS:
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3.8.1.
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CPPD Response: The annotation, 'Wloved to ITS: 3.8.1," in the CTS markups for ITS 3.3.5.1 signiRes that the CTS information is dispositioned
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in the CTS markups and discussions of changes for ITS: 3.8.1. Specincelly, Discussion of Changes (DOCS) A.5 and L11 for ITS 3.8.1 as well as ITS SR 3.81.11 address the subject requirements in CTS Tables 3.2.B and 4.2.B related to low voltage on an indhnduel bus / component.
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Cooper Nuoleer Ctat#on improvind TS Review Comments ITS 3.3.5.1, Emergency Core Cooling System (ECCS) instrumentation 3.3.5.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 6
5 STS SR 3.3.5.1.7 Justify, based on Genenc ITS 3.3.5.1 Studies and Design Safety Analysis, not irmpOniiting STS SR 3.3.5.1.7, on Response Time Testing (RTT), has not been RTT in the iTS.
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added to the ITS because RTT is not in the CTS, and based on i
" Generic Studies."
NPPD Response: The generic studies that Justification for Deviation (JFD) 5 references for ITS 3.3.5.1 are those that NEDO-32291 discusses, i
" System Andysis for Elimination of Selected Response Time Testing Requirements," dated January 1994. CNS did not participate in the NEDO-32291 evaluation. In addition, the CTS do not include response time testing requirements for ECCS instrumentation, and NPPD does not choose to adopt these additional requirements.
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Cooper Nuolear Station improved TS Review Comments sm_o.aws ITS 3.3.5.2, Reactor Core isolation Cooling System Instumentation 3.3.5.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1
t.AV CTS Table 3.2.B. Setting Limits Acceptabildy of the changed ITS Table 3.3.5.2-1, Allowablo Values setpoints/ allowable values is contingent upon the NRC The CTS setting limits for RCIC Functions are changed in detenniaing acceptable appicabon ITS Table 3.3.5.2-1 to reflect new CNS Allowable Values of the GE Setpoint "." 3.cdoicgy.
based on the GE Instrument Setpoint Methodology. The followmg CTS RCIC Function setting runits listed in CTS Table 3.2.B m changed in ITS Table 3.3.5.2-1:
Reactor Low Water Level Reactor High Water Level Emergency Condensate Storage Tank Low Level NPPD Response: No response required. NPPD consders this comment to be for intemal NRC issue tracking purposes. See the added response to item Number 3.3.1.1-2.
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Cooper Nuolear Stat *on improved TS Review Comments mo.aws ITS 3.3.5.2, Reactor Core isolation Cooling System Instrumentation I
3.3.5.2 DOC JFD CHANGE / DIFFERENCE '
COMMENT STATUS 2
2 STS Table 3.3.5.2-1 Function 5 include the Manual initiation iTS Table 3.3.5.2-1 Function in ITS 3.3.5.2, consistent Bases 3.3.5.2 with the STS and Bases, or provide i
system design WEjustification l
STS Table 3.3.5.2-1, includes Function 5, Manual Initisbon for not adopting the STS and of RC.lC. ITS Table 3.3.5.2-1 deletes this Function..There is associated Bases.
i no justification based on CNS specific plant design to substantiate this deviation from the STS. The STS 3.3.5.2 l
Bases for this Function states that the Function is not typcally assumed in any accident or transient analyses in the FSAR and that the Function is retained in the TS for overail redundancy and diversity of the associated RCIC Function as required by the NRC in the plant licensing basis.
i NPPD Response: The CNS design does not include the single pushbutton manual actuation instrumentshon function the ISTS Bases for LCO 3.3.5.2 describes for the Reactor Core Isolation Coohng System. NPPD changed the ISTS to reflect the plant-spacii design.
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Cooper Nuclear Station improved TS Review Comments at_oeies ITS 31621, Primary Containment isolation instrumentation 3.3.4.1 DOC JFD CHANGE / DIFFERENCE CORA4ENT STATUS 1
1.AV CTS Tat,!s 3.2.A Acceptability of the changed ITS Table 3.3.6.1-1 Allowable Values is contingent upon the NRC detemiining The CTS Setting Limits for many Primary Containment Isolation acceptable appfcation of the GE Instrumentation (PCil) Functions are changed in ITS Table instrumentation Setpoint 3.3.6.1-1 to reflect new Allowable Values. The new ITS Methodology.
Alicwable Values are based on the GE Instrument Setpoint Methodology. The following CTS PCII Setting Limits listed in CTS Table 3.2.A are changed in ITS Table 3.3.6.1-1, by ITS Table 3.3.6.1-1 Function number: 1a,1b,1c,1d,1e,2a,2b 2d, Se,5b,5d,6a,6b.
NPPD Response: No response required. NPPD considers this comment to be for intemal NRC issue tracking purposes. See the added response to item Number 3.3.1.1-2.
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STS Table 3.3.6.1-1, Function 5.f include the Manualisolation ITS 3.3.6.1 Functions in the ITS, consistent Bases 3.3.6.1 with the STS and Bases or provide system design specife STS Table 3.3.6.1-1, Function 5.f. Reactor Water Cleanup justircation for not adopting the Systo..: isciation, Manual Initiation is not included in ITS 3 'N.1.
STS and associated Bases.
Justification for the omissir n is based on current licensing basis, and the fact that this Manual Initiation Function is not credited in the safety analysis. The STS 3.3.6.1 Bases for this function states that these Functions are not typcally assumed in any accxient or transient analyses in the FSAR and that the function is retained in the TS for overall redundancy and diversity of the associated RWCU Functions as required I.? the NRC in the plant rcensing basis.
NPPD Response: The CNS design does not include the pushbutton manual actuation instrumentation function desenbed in the ISTS Bases for LCO 3.3.6.1 for isolation of the Reactor Water Cleanup System. NPPD made the change to the ISTS to reflect the plant-specific design.
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Cooper Nuclear Station improved TS Review Comments am p. anes ITS 3.3.6.1, Primary Containment isolation instrume h 3.3.5.1 DOC l JFD CHANGF> DIFFERENCE COMMENT STATUS
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STS SR 3.3.6.1.8 Justify, based on Generic ITS 3.3.6.1 Studies and Design Safety Analysis, not incvipui. ting RTT STS SR 3.3.6.1.8, on Response Time Tading (RTT) has not in the ITS.
been added to the ITS because RTT is r** ;i the CTS, and based on " Generic Studies."
NPPD Response: The generic studies that Justification for Deviation (JFD) 5 references for ITS 3.3.5.1 are those that NEDO-32291 discusses,
" System Analysis for Elimination of Selected Response Time Testing Requirements," dated January 1994. CNS did not participate in the l
NEDO-32291 evaluation. In addition, the CTS do not include response time testing requiremects for pnmary contaicment isolation instrumentation, and NPPD does not choose to adopt these additional requirements.
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Cooper Nuclear Station improved TS Revimw Comments ITS 3.3.4.2, Secondary Containment isolation Instrumentation 3.3.4.2 DOCI JFD CHANGE / DIFFERENCE COMMENT STATUS-1 6
STS SR 3.3.6.2.7 Justify, based on Genenc ITS 3.3.6.2 Studies and Desegn Safety Analysis, not incorporating RTT STS SR 3.3.6.2.7, on Response Time Testing (RTT) has not been in the ITS.
added to the ITS because RTT is not in the CTS, and based on
" Generic Studies."
NPPD Response: The generk-dudie, that Justification for Deviation (JFD) 5 references for ITS 3.3.5.1 are those that NEDO-32291 discusses.
" System Analysis for Elimination of Selected Response Time Testing Requirements," dated January 1994. CNS did not participate in the NEDO-32291 evaluation. In addi* ion, the CTS do not include response time testing requirements for secondary containment isolation instrumentation, and NPPD does r ot choose to adopt these additional requirements.
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STS 3.3.6.2.2 Action B Adopt the STS wording or ITS 3.3.6.2.2, Action B initiate a genere change package for the STS deviation.
STS 3.3.6.2.2 Action B, requires restoring secondary containment isolation within one hour when one or more automatic Functions with secondary containment isolation capability not mamtained.
Corresponding requirement, ITS 3.3.6.2.2, Action B, requires restoring isolation capability within one hour when one or more Functions with isolation capability is not maintained.
Deleting the words " automatic" and " secondary containment
NPPD Response: in a revision to the CNS ITS submittal, NPPD will revise ITS 3.3.6.2 Condition B and Required Action B.1 to adopt the ISTS wording.
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l Cooper Nuclear Station improved TS bo:ew Comments mo.se ITS 3.3.6.2, Secondary Containment isolation instrumentation 3.3.8.2 DOC JFD CHANGE / DIFFERENCE CORWl4ENT STATUS 3
8 STS Table 3.3.6.2-1. Function 5 Include the Manualisolation l
lTS 3.3.6.2 Functions in the ITS. consistent STS 3.3.6.2 Bases with the STS and Bases or Provide system design WTic STS Tabla 33.6.2-1. Function 5, Manual Initiation for Secondary justircahon for not adopting the Containrnent isolation is not included in ITS 3.3.6.2. Justifcation STS and associated Bases.
for the omission is based on current licensing basis, and the fact that this Manual initiarion Function is not credited in the safety analysis. The STS 3.3.6.2 Bases for this function states that these Functions are not typcally assumed in any accklent or transient analyses in the FSAR and that the functbn is retamed in the TS for overall redundancy and diversity of the associated Secondary Containment isolation Functions as required by the NRC in the plant fcensing basis.
. NPPD Response: The CNS design does ot include the pushbutton manual actuation instrumentation function desenbed in the ISTS Bases for
- LCO 3.3.6.2 for isolation of secondary containment. Therefore. NPPD made the change to the ISTS to reflect the plant specific design.
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Cooper Nuclear Station fu.risced TS Review Comments mcmm ITS 3.3.6.2, Secondary Containment isolation instrumentation
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3.3.4.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 4
2 CTS Table 3.2.D Has there been a change in the STS Table 3.3.6.2-1 plant specific nomenclature?
ITS Taale 3.3.6.2-1 l
CTS Table 3.2.D list requirements for Reactor building isolation and Standby Gas Treatment initiation systems.
STS Table 3.3.6.2-1 equivalent Function is Reactor Building Exhaust Radiation - High.
ITS Table 3.3.6.2-1 renames tha FTS Function as Reactor Building Ver:tilation Exhaust plenum R,sion - High.
Why the CTS Function nomenclature is not maintained in the ITS is not clear.
NPPD Respoew: The ITS prevides the plant-specific terminology of the subject instrumentation function for Emergency Opemting Procedure entry at CNS (Reactor Building Ventilation Exhaust Plenum Radiation -High), in place of the CTS general description of the function (Reactor Building Iso lation and Standby Gas Treatment initiation System).
5 LAV CTS Table 3.2.A Acceptabilityof thechanged CTS Table 3.2.D Allowable Values is contingent ITS Table 3.3.6.2-1 roon the NRC determining accgtable application of the CTS Table 3.2.A and D, setting limits for Reactor Low Water Level, GE Setooint Methodology.
High Drywell Pressure, and Reactor Building isolation and Standby Gas Treatment initiation are changed on ITS Table 3.3.6.2-1 to reflect new CNS Allowable Values based on the GE Se' point Methodology. This is a deviation from the CTS Allowable Values.
NPPD Response: No response required. NPPD considers this comment to be for intemal NRC issue tracking purposes. See the added response to item Number 3.3.1.1-2.
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Cooper Nuclear Station improved TS Review Comments suspenes ITS 3.3.6.3, Low-low Set inatrumentation 3.3.6.3 DOC JFD CHANGEIDIFFERENCE COMMENT STATUS 1
LAV CTS 3.7.A.6.b Acceptabilityof thechanged ITS Table 3.3.6.3-1 setpoints/ allowable values is contingent upon the NRC detenmning The CTS trip setting limits for the LLS Instrumentation in acceptable application of the GE CTS 3.7.A.6.b are changed in ITS Table 3.3.6.3-1 to reflect Setpoint Methodology documented in new Allowable Values based on the CNS Setpoint NEDC41336.
Methodology Program. Justification provided indicates that the new values are established consistent with the GE Setpoint Methodology NPPD Response: No response required. NPPD considers this comment to be for intemal NRC issue tracking purposes. See the a(J.
response to item Number 3.3.1.1-2.
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Cooper Nuclear Station improved TS Review Comments un_oem ITS 3.3.7.1, Control Room Emergency Fth System Instrumen*.aten
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3.3.7.1 DOC JFD CHANGE /DtFFERENCE COMMENT-STATUS 1
LAV CTS Tat,;e 3.2.D Acceptance of this change is STS Table 3.3.7.1-1 contingent upon the NRC review and ITS Table 3.3.7.1-1 applicability of the GE set point methodology.
ITS Table 3.3.7.1-1 includes the CREF System Instrumentation broken down into three channels,1)
Particulate 2) Gaseous 3) lodine, all with their individual Allowable Values. Justification provided indicates that the new values are established consistent with the GE Setpoint Methodology.
NPPD Response: No response required. NPPD considers this comment to be for intemal NRC issue track;mg purposes. See the added response to item Number 3.3.1.1-2.
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Cooper Nuclear Station improad TS Review Comments mi_oem ITS 3.3.8.1, Loss of Power Instramentation 3.3.8.1 DOC JFD CHANGE / DIFFERENCE -
COMMENT-STATUS I 1
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CTS Table 3.2.B Acceptance of this change is contingent ITS Table 3.3.8.1-1 upon the NRC review and applicability STS Table 3.3.8.1-1 of the GE set point.TintWy.
ITS Table 3.3.8.1-1 includes func. ns of the applicable CNS e
LOP instrumentation with individual Allowable Values. The justification states that Allowable Values were derived utilizing the GE Instrumentation Setpoint Methodology.
NPPD Response: No response required. NPPD considers this comment to be for intemal NRC issue tracking purposes. See the added response to item Number 3.3.1.1-2.
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Cooper Nuclear Ctation improved TS Review Comments 3mpears '.
ITS 3.3.8.1, Los3 of Power lastrumentation t
3.3.8.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 2
L2 CTS Table 4.2.8 Similar allowances are based on a ITS 3.3.8.1 SR Note 2 reliability study contained in GENE ~70-06-1-A, dated December 1992. Is this A note is added to the ITS 3.3.8.1 SR's allm.g a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> extension based upon a reliability delay prior to entering the associated Required Actions for a study?
channel placed in an Inoperable status for performance of l
required Surveillances, provided the associated Function maintains initiation capability for one of the DG's or under voltage transfer capability for one of the emergency buses.
CTS Table 4.2.B does not allow 2 %s, of Inoperability to perform surveillances before enter.. g Required Actions, but would require immediately declaring the associated DG Inoperable under the same conditions. No reliability study is referenced in the DOC for this extention.
NPPD Response: While the showance that Note 2 provi@ v the ITS 3.3.8.1 Surveillance Requirements is similar to those allowances provided in GENE-770-06-1-A, dated December 1992, it has no basis on a reliability study. This allowance is the same as that provided in Note 2 to the ISTS 3.3.8.1 Surveillance Requirements. The allowance in ISTS 3.3.8.1 is also not based on a reliability study.
Coooer Nuclear Station improved TS Review Comments mo.s e ITS 3.3.8.2, Reactor Protection System Electric Power Monitoring 3.3.8.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS l
1 LAV CTS 4.9.A.4.a.1, 2, and 3 Acceptance of this change is ITS SR 3.3.8.2.1 s. b, a id c contingent upon the NRC review and applicability of the GE set point CTS 4.9.A.4.a requires performing a Channel Calibration methodology once every operating cycle and includes Setpoints and time delays for Over-voltage. Under-voltage, and Under-frequency. ITS SR 3.3.8.2.1 requires performing the same Channel Calibration once every 18 months and lac 8udes Allowable Values. Justification provided indicates that the new values are established consistent with the GE Setpoint Methodology.
NPPD Response: No response required. NPPD considers this comment to be for intemal NRC issue tracking purposes. See the added I
response to item Number 3.3.1.1-2.
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e' Cooper Nuclear Sta+ ion improved TS Review Comments nerpaws ITS 3.3.8.2, Reactor Protection System Electric Power M%
g 3.3.8.2 DOC JFD CHANGE / DIFFERENCE -
COMMENT STATUS 2
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CTS 3.9A 1 This change to CTS requimments also ITS 3.3.8.2 Applicability results in a deviation from the STS.
STS 3.3.8.2 Applicability Approval of this change is contingent upon approvalof a genaricTSTF CTS 3.9.A.1 requires the power monitoring ystem for the incorporating this change into the inservice RPS MG set or attemate source be Operable in STS.
Modes 1,2, and 3 (the reactor shall not be made critical from a Cold Shutdown Condition). ITS 3.3.8.2 Applicability is Modes 1,2, and Mode 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies. STS 3.3.8.2 Applicability is Modes 1,2, and 3 and Modes 4 and S
[with any control rod withdrawn from a core cell containing one or more fuel assemblies). ITS 3.3.8.2 deletion of Modes 3 and 4 is based on a control rod block in Mode 3 preventing control rod withdrawal, and the availability of ITS 3.10.3 and ITS 3.10.4 if a CR were to be intentionally withdrawn.
1 NPPD Response: As DOC L1 for ITS 3.3.8.2 discusses, the change to the Applicability of CTS 3.9.A.1 is consistent with the CTS Bases,
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l which states that the RPS electric power monitoring assemblies are required OPERABLE to support the RPS. Therefore, NPPD does not consider the current licensing basis for the RPS electrical power monitoring assentblies to include requirements to protect equipment other than that associated with RPS. The change to the ISTS, which the CNS ITS reflects, is only applicable for plants where the RPS ehetric power monitoring assemblies are only required OPERABLE to support the RPS. !STS 3.3.8.7 was written for plants where the RPS el tric power assemblies are needed to assure both the RPS and RPS-bus-powered ccManents 7:.h as isolation logic for the RHR shutdc
- coling isolation valves, are protected from electrical excurr'
's. Therefore, this cMage to the ISTS is not generic and should be processad as a plant-specific change.
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