ML20210L870
| ML20210L870 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/25/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20210L867 | List: |
| References | |
| TAC-57610, NUDOCS 8610030323 | |
| Download: ML20210L870 (5) | |
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uq#o UNITED STATES g
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g NUCLEAR REGULATORY COMMISSION g
p WASHINGTON, D. C. 20655
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l
SUPPORTING AMENDMENT NO.102 TO FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT i
COOPER NUCLEAR STATION i
DOCKET NO.50-298 i
1.0 INTRODUCTION
j By letters dated April 26,1985, May 24,1985, June 14,1985 and July 3, j
1986 the Nebraska Public Power District (the. licensee) requested an amendment to Facility Operating License No. DPR-46 for the Cooper Nuclear Station (CNS). The proposed amendment would change the Technical Specifications in the following areas:
(1) Standb (SGTS) and Control Room Ventilation System (CRVS) y Gas Treatment System operability and surveillance requirements:
(2) Reactor Water Sample Line Isolation trip setting; (3) Refueling Interlocks requirements; (4) Equipment i
Qualification (EQ) deadline; (5) Typographical errors, and (6) Table of i
Contents corrections.
j 2.0 DISCUSSION AND EVALUATION SGTS and CRVS f
i The licensee has requested changes to the Technical Specifications applicable i
to these systems as follows:
(1) Section 3.7.B.2.a would be changed to clarify that the in-place leak tests on HEPA filters and charcoal adsorbers of
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the Standby Gas Treatment System shall be conducted at equal to or less than design flow (1780 CFM) and at a reactor building pressure equal to or l
less than -0.25 inch water gauge.
The existing specification requires that j
the tests be conducted "at design flow." (2) Section 3.7.B.2.b would be changed to clarify that the SGTS carbon sample laboratory analysis be conducted with an inlet velocity of equal to or greater than 42 FPM. The.
l existing specification requires that the analysis be conducted "at a velocity within 20 percent of actual systems design." (3) Section 3.7.B.2.c would be i
changed to clarify that each SGTS fan be shown to provide-1780 CFM plus or i
minus 10%. The existing specification requires that each fan be shown to
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" operate within + 10% of design flow." (4) The Bases for Sections 3.7.B and 3.7.C would be changed to clarify that the SGTS in-place tests should indicate a HEPA filter efficiency of at least 99 percent removal of DOP.
It would be deleted that operation of the fans significantly different from the design i
flow will change the removal efficiency of the HEPA filters and the charcoal i
adsorbers.
(5) Bases for Sections 4.7.B and 4.7.C would be chang?d to clarify j
the references to Regulatory Guide 1.52, Revision 2 March 1978.
(6)Section
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3.12.A.2.a would be changed to clarify that the in-place leak tests on the HEPA filters and the charc6al adsorbers of-the Main Control Rooa Ventilation System shall be conducted at equal to less than design flow (341 CFM) 8610030323 860'725 DR ADOCK 000 8
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, l and at control room pressure.
The existing specification requires that i
the tests be conducted "at design flows." (7) Section 3.12.A.2.b would be changed to clarify that the CRVS laboratory carbon sample analysis be conducted with an inlet velocity of equal to or greater than 22 feet per 1
minute. The existing specification requires that the anlysis be conducted i
"at a velocity within 20 percent of system design." (8) Section 3.12.8.2.c would be changed to clarify that each CRVS fan be shown to provide 341 CFM plus or minus 10%.
The existing specifications requires each fan to
" operate within plus or minus 10% of design flow." (9) Bases for Section 4
3.12. A would be changed to clarify that the in place tests should indicate a HEPA filter efficiency of at least 99 percent removal of DOP.
It would be deleted that operation of the fans significantly different frcm the
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design flow will change the removal efficiency of the HEPA filters and the charcoal adsorbers.
The Standard Technical Specifications for General Electric BWRs (NUREG-0123) i specifies that for in place testing of ESF f 0ter systems, such as for the SGTS and the CRVS, the system flow rate be the design flow (appropriate
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value given) plus or minus 10L There are no provisions governing flow i
conditions under which the carbon samples are analyzed other than by l
reference to Regulatory Guide 1.52, which states that the sample should be exposed to the same service conditions cs the adsorber section.
There is a provision for verifying the system flow rate to be (appropriate design value given) plus or minus 10L Rcgulatory Guide 1.52, Revision 2, in each of the provisions under "In-Place Testing Criteria" refers to ANSI-N510-1975.
The r,ignificance of the in place leak tests is addressed in Appendix B of ANSI-N510-1975.
The in place field tests of installed HEPAs do not show the efficier.cies of the filters but only "eual the i
presence of leaks in'the system.
The in place field tests of n. stalled adsorbers are designed to determue only the amount of Ita! y through or around the installed bank of cells.
Poor HEPA filter or charcoal adsorber t
performance is not detected by the7e tests.
With HEPAs, it can be inferred that the particle-removing efficiency of the system is equivalent to tnat of the individual filters if penetration
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observed in the in place test is equivalent to the penetration established l
j during factory testing of the inlividual filters.
For adsorbers, true i
efficiency tests are run en small representative samples of adsorbent. An j
installed system can be assumed to have an efficiency equivalent to that of the sample only if (1) the laboratory sample is representative, (2) the i
adsorber cells are tightly packed, and (3) there are no leaks or bypasses in the factory test of leakage throu O or around the adsorbent in the cell or the in place test of leakage through or around the installed bank of l
cells.
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i While particle collection efficiencies and charcoal adsorbent efficiencies may be highly dependent on the airflow rate, the leakage rate relative to the airflow rate should not vary significantly with the airflow rate for a dimensionally stable system. ANSI-N510-1975 does not prescribe an airflow rate for the in place leak tests for either the HEPA filter banks or the l
installed adsorber stage.
ERDA 76-21, " Nuclear Air Cleaning Handbook,"
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. referred to by Regulatory Guide 1.52, states that for HEPA filters the in place tests can be made at rated system airflow or at reduced flow.
Some agencies test at as low as 5 to 10% of rated system airflow.
The The licensee has reviewed the Cooper SGTS and CRVS filter and filter housing designs.
In a letter dated July 3, 1986, the licensee verified that they are dimensionally stable and have no loop seals or other features that could allow higher bypass leakage rates at design airflow than would be determined by in place leak tests at any lower airflow rate.
Therefore, the chances (1) and (6) to Sections 3.7.B.2.a and 3.12.A.2.a to conduct the in place leak test at equal to or less than design flow are acceDtable.
The licensee's submittal states that the filterface velocity of 42 FPM for the SGTS eorresponds to the design flow rate of 1,780 CFM and that the filterface velocity of 22 FPM for the CRVS corresponds to the design flow rate of 341 LFM.
Laboratory testing of carbon samples at inlet velocities equal to or in excess of the above filterface velocities is acceptable since residence times during testing will not be in excess of in service residence times and, therefore, the carbon filter efficiencies obtained during laboratory testing will be expected to be equaled or exceeded in service.
Therefore, the changes (2) and (7) to Sections 3.7.B.2.b ar.d 3.12.A.2.b to conduct laboratory carbon sample analyses at inlet velocities corresponding to design flow rates are acceptable.
The other proposed changes:
(3), (4), (5), (8) and (9) are of an editorial nature, are consistent with current requirements and are also acceptable.
Reactor Water Sample Line Water Level Trip Setting The reactor water sample line primary containment isolation valves are NORMALLY CLOSED air operated valves.
They are required by Technical Specifications to automatically isolate on a high main steam line radiation signal or a low-low (-37 in.) reactor vessel water level signal.
The licensee has requested that the Technical Specifications be changed to specify that the latter (reactor water level isolation function) occur at the low-low-low
(-145.5 in.) setpoint.
The effect of the setpoint reduction would be an additional delay in sample line isolation should a reduction in reactor vessel inventory event occur.
However, in the case of a small break outside containment, such as the 3/4-inch sample line, no significant reduction in i
vessel level would occur. The event would be terminated by manual isolation on other indications (i.e. high secondary containment radiation levels or temperature levels, increased reactor makeup water requirements, or visual observation by roving patrols) as indicated in the applicable protective action sequence (ref. Cooper USAR Appendix G).
Therefore, changing the reactor vessel level setpoint for sample line isolation would not adversely affect the consequences of a sample line break.
The amendment is therefore acceptable.
Refueling Interlocks _
The current CNe echnical Specifications require that all refueling interlocks, with the exception of the one rod out interlock, be operable
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..during multiple control rod removal regardless whether fuel is or is not in the vessel. The amendment would delete this requirement for periods when there is no fuel in the reactor vessel. The objective of the interlocks, as stated in the Technical Specifications, is to ensure that reactivity control is within the capability of the control rods and to prevent inadvertent criticality during refueling operations. With no fuel in the vessel no core reactivity is available.
The change is therefore acceptable.
Environmental Qualification Deadline Section 6.3.7.C of the CNS Technical Specifications presently contains a June 30, 1982 EQ deadline. That requirement was placed in the CNS Technical Specifications by an Order dated October 24, 1980. However, the June 30, 1982 deadline was superseded by 10 CFR 50.49(g). The licensee requests that 6.3.7.C be deleted. With the Rule in effect, this would be a purely administrative change and would have no effect on the actual EQ program requirements. The change is therefore acceptable.
Typographical Errors To correct typographical errors, the licensee requests the following changes (1) In 4.4 Bases, Standby Liquid Control System change "III.8.5" to "III.9.5";
and (2) In Table 4.2.B (Page 6) change " Logic Buss Power Monitor" to " Logic Bus Power Monitor" These changes have no safety significance and are acceptable.
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Reformat of Administrative Controls Subsections 4
Section 6, " Administrative Controls" of the CNS Technical Specifications has undergone various revisions which have introduced discontinuities between the pages of some subsections.
The licensee proposes to make editorial changes which condense related subsections. The content of the material would not be changed.
Page 225a would be deleted as a result of compressing its contents into fewer pages. The proposed change would improve readability and comprehension of the Technical Specifications and is acceptable.
3.0 ENVIRONMENTAL CONSIDERATION
S This amendment changes a requirement with respect to installation or i
use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
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4.0 CONCLUSION
We have concluded, based in the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be i
endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be inimical to the common defense and security or 4
to the health and safety of the public.
Principal Contributer:
W. Long, L. Lois, C. Nichols, J. Lane Dated: September 25, 1986 i
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