ML20282A176
| ML20282A176 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/22/2020 |
| From: | Thomas Wengert Plant Licensing Branch IV |
| To: | Dent J Nebraska Public Power District (NPPD) |
| Lingam S, NRR/DORL/LPL4, 415-1564 | |
| References | |
| EPID L-2020-LLA-0082 | |
| Download: ML20282A176 (22) | |
Text
October 22, 2020 Mr. John Dent, Jr.
Vice President-Nuclear and Chief Nuclear Officer Nebraska Public Power District 72676 648A Avenue P.O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT NO. 267 RE:
ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)
TRAVELER TSTF-529, REVISION 4, CLARIFY USE AND APPLICATION RULES (EPID L-2020-LLA-0082)
Dear Mr. Dent:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 267 to Renewed Facility Operating License No. DPR-46 for the Cooper Nuclear Station (Cooper). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated April 1, 2020.
The amendment revises Cooper TS Sections 1.3, Completion Times, and 3.0, Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR) Applicability.
Specifically, these changes clarify and expand the use and application of the Cooper TS usage rules and are consistent with NRC-approved Technical Specifications Task Force (TSTF)
Traveler TSTF-529, Revision 4, Clarify Use and Application Rules. TSTF-529, Revision 4, was approved by the NRC on April 21, 2016.
J. Dent, Jr. A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Thomas J. Wengert, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosures:
- 1. Amendment No. 267 to DPR-46
- 2. Safety Evaluation cc: Listserv
NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 267 Renewed License No. DPR-46
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Nebraska Public Power District (the licensee),
dated April 1, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
Enclosure 1
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-46 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 267, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Digitally signed by Jennifer L. Dixon-Herrity Dixon-Herrity Date: 2020.10.22 16:55:25 -04'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License No. DPR-46 and the Technical Specifications Date of Issuance: October 22, 2020
ATTACHMENT TO LICENSE AMENDMENT NO. 267 RENEWED FACILITY OPERATING LICENSE NO. DPR-46 COOPER NUCLEAR STATION DOCKET NO. 50-298 Replace the following pages of the Renewed Facility Operating License No. DPR-46 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 1.3-1 1.3-1 1.3-2 1.3-2 1.3-3 1.3-3 3.0-2 3.0-2 3.0-4 3.0-4
(5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.
C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2419 megawatts (thermal).
(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 267, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: Cooper Nuclear Station Safeguards Plan, submitted by letter dated May 17, 2006.
NPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NPPD CSP was approved by License Amendment No. 238 as supplemented by changes approved by License Amendments 244 and 249.
(4) Fire Protection NPPD shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated April 24, 2012 (and supplements dated July 12, 2012, January 14, 2013, February 12, 2013, March 13, 2013, June 13, 2013, December 12, 2013, January 17, 2014, February 18, 2014, and April 11, 2014), and as approved in the safety evaluation dated April 29, 2014.
Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if Amendment No. 267
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g.,
inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Tim begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
(continued)
Cooper 1.3-1 Amendment No. 267
Completion Times 1.3 1.3 Completion Times DESCRIPTION If situations are discovered that require entry into more than one (continued) Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
- a. Must exist concurrent with the first inoperability; and
- b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the
( continued)
Cooper 1.3-2 Amendment No. 267
Completion Times 1.3 1.3 Completion Times DESCRIPTION Completion Time is referenced from a previous completion of the (continued) Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Condition A and B in Example 1.3-3 may not be extended.
EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and associated Completion AND Time not met.
B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.
The Required Actions of Condition Bare to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for reaching MODE 4 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
(continued)
Cooper 1.3-3 Amendment No. 267 L
LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 a. When the associated ACTIONS to be entered permit continued (continued) operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or
- b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or
- c. When an allowance is stated in the individual value, parameter, or other Specification.
This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)."
If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
(continued)
Cooper 3.0-2 Amendment No. 267 L
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.
Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval* specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... "
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.
A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
(continued)
Cooper 3.0-4 Amendment No. 267
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 267 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION
By application dated April 1, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20111A145), Nebraska Public Power District (the licensee) requested changes to the Technical Specifications (TSs) for Cooper Nuclear Station (Cooper).
The proposed changes would revise Cooper TS Sections 1.3, Completion Times, and 3.0, Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR)
Applicability. Specifically, these changes would clarify and expand the use and application of the Cooper TS usage rules and are consistent with the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, Revision 4, Clarify Use and Application Rules, dated February 29, 2016 (ADAMS Accession No. ML16062A271). TSTF-529, Revision 4, was approved by the NRC by letter dated April 21, 2016 (ADAMS Accession No. ML16060A441).
2.0 REGULATORY EVALUATION
2.1 Description of the Subject TS Sections LCOs specify minimum requirements for ensuring safe operation of the unit. The actions associated with an LCO state conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated condition are required action(s) and completion time(s).
Cooper TS Section 1.3, Completion Times, currently describes completion times, in part, as follows:
The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Required Actions must be Enclosure 2
completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.
Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.
Cooper TS LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all specifications and apply at all times, unless otherwise stated. Similarly, SR 3.0.1 through SR 3.0.4 establish the general requirements for surveillances that are applicable to all specifications and apply at all times, unless otherwise stated.
2.2 Description of Proposed TS Changes The proposed changes will revise Cooper TS Sections 1.3 and 3.0. The proposed changes are described in more detail below.
2.2.1 Proposed Changes to Time of Discovery Cooper TS Section 1.3, Description, currently states, in part, the following (with emphasis added on time of):
The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Cooper TS Section 1.3, Description, also currently states, in part, the following (with emphasis added on time of):
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.
The licensees proposed change to Cooper TS Section 1.3 would delete time of from the previous statements and would read as follows:
The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
[]
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition.
The adequacy of this change is discussed in Section 3.1.1.1 of this safety evaluation (SE).
2.2.2 Proposed Addition to Time of Discovery The licensee proposed to add the following paragraph to Section 1.3 of the Cooper TSs under
==
Description:==
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.
The otherwise specified exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, AC [Alternating Current] Sources - Operating, Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
The proposed change augments the NRC staffs expectation that a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and a Condition is entered.
The adequacy of this change is discussed in Section 3.1.1.2 of this SE.
2.2.3 Proposed Addition of Unless Otherwise Specified Cooper TS Section 1.3, Description, currently states the following (with emphasis added on unless otherwise specified):
The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
The licensee proposed to add, in part, the following sentence right after the above statement to Cooper TS Section 1.3, which contains the phrase unless otherwise specified:
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.
In addition, the licensee proposed adding the phrase unless otherwise specified to the following two statements:
When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.
and The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
The adequacy of this change is discussed in Section 3.1.1.3 of this SE.
2.2.4 Proposed Changes to LCO 3.0.4 Cooper TS LCO 3.0.4 currently states, in part:
When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
- b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or
The licensee proposed to clarify LCO 3.0.4.b by placing the statement regarding exceptions in parentheses and deleting the first semicolon after appropriate. The proposed Cooper TS LCO 3.0.4 would state, in part, the following:
When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
- b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or The adequacy of this change is discussed in Section 3.1.2 of this SE.
2.2.5 Proposed Changes to SR 3.0.3 Cooper SR 3.0.3 currently states, in part, the following:
If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
The licensees proposed changes to Cooper SR 3.0.3 would state, in part, the following (the additional sentence is underlined):
If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.
A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
The adequacy of this change is discussed in Section 3.1.3 of this SE.
2.3 Regulatory Requirements, Licensing Information, Guidance Documents The NRC staff considered the following regulatory requirements, guidance, and licensing information during its review of the proposed changes:
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c), requires TSs to include the following categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports.
Section 50.36(c)(2) of 10 CFR states, in part, that:
Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
Section 50.36(c)(3) of 10 CFR states that:
Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The NRC staffs guidance for the review of the TSs is in NUREG-0800, Standard Review Plan
[SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Chapter 16, Technical Specifications, Revision 3, dated March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared improved standard technical specifications (STSs) for each of the LWR nuclear steam supply systems and associated balance-of-plant equipment systems. The licensees proposed amendment is based on TSTF-529, Revision 4, which is an NRC-approved change to the improved STSs. The NRC staffs review includes consideration of whether the proposed changes are consistent with TSTF-529, Revision 4.
Special attention is given to TS provisions that depart from the improved STSs, as modified by NRC-approved TSTF travelers, to determine whether proposed differences are justified by uniqueness in plant design or other considerations so that 10 CFR 50.36 is met. In addition, the guidance states that comparing the change to previous STSs can help clarify the TS intent.
3.0 TECHNICAL EVALUATION
During the review of TSTF-529, Revision 4, the NRC staff considered generally the guidance on acceptance criteria of the SRP sections described in Section 2.3 of this SE, and, in particular, the acceptance criteria in Chapter 16 of NUREG-0800, Revision 3. Additionally, the NRC staff evaluated the proposed changes to the Cooper TSs against the STSs, as modified by approved TSTF-529, Revision 4 changes, as well as the requirements of 10 CFR 50.36(c).
3.1 Requested Changes 3.1.1 Proposed Changes to Section 1.3 3.1.1.1 Proposed Changes to Time of Discovery The only mention of the term time of discovery in relation to completion times is in Cooper TS Section 1.3 (quoted in Section 2.2.1 of this SE). Throughout the Cooper TSs, the term discovery is used to describe the point in time when it is recognized that the requirements of an LCO are not met. For example, TS LCO 3.0.2 states in part that Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. In addition, the Bases to LCO 3.0.2, state, in part,
LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met.
The proposed change to Cooper TS Section 1.3 would delete time of from the previous statements. The NRC staff finds the proposed change acceptable because it makes Section 1.3 consistent with the language used throughout the rest of the TSs. This provides clarity to the term discovery, and therefore, provides a clear and objective application of the TS Required Actions and associated Completion Times. The change is editorial and has no effect on the requirements currently in the TSs. The change also adopts an approved TSTF-529 change to the Cooper TSs. Therefore, the NRC staff finds the proposed change acceptable.
3.1.1.2 Proposed Addition to Discovery The proposed addition of the paragraph quoted in Section 2.2.2 of this SE is a TSTF-529 approved change.
The operating shift crew is responsible for overall control of facility operation. As part of that responsibility, the operating shift crew must be aware of the status of the plant and condition of structures, systems and components. This includes status of degraded or nonconforming conditions that may affect plant operation. Therefore, the proposed change simply augments the NRC staffs expectation that a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and a condition is entered. The phrase and an ACTIONS Condition is entered in the above proposed insertion is necessary to accommodate circumstances in which LCO 3.0.6 allows an LCO to not be met without entry into the Conditions. In those circumstances, a completion time does not begin. In addition, an example is added to the proposed insertion in order to explain the concept presented.
The NRC staff finds the proposed change acceptable since it clarifies senior reactor operators responsibilities and the allowances of LCO 3.0.6, and therefore, provides a clear and objective application of Coopers TS required actions and associated completion times and it adopts an approved TSTF-529 change to the Cooper TSs.
3.1.1.3 Proposed Addition of Unless Otherwise Specified The phrase, unless otherwise specified, in Cooper TS Section 1.3, refers to those instances in which TS LCOs define the start of the completion time as different from discovery. For example, Cooper TS 3.8.1, AC Sources - Operating, Required Action B.2, calls for declaring required feature(s) supported by an inoperable diesel generator inoperable when the redundant required feature(s) are inoperable. The Completion Time states, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). In this case, the Completion Time does not begin until the conditions in the completion time are satisfied.
The licensee proposed adding the phrase unless otherwise specified, to the paragraphs described in Section 2.2.3 of this SE. The addition of the phrase unless otherwise specified acknowledges that there are instances, as indicated in the individual TSs, when the completion time does not start at discovery. These exceptions are varied, such as when a Required Action Note or SR Note provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a condition be applicable for any
reason not addressed by the Note, the completion time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point.
The NRC staff approved the addition of the phrase to the STSs in TSTF-529. The NRC staff finds the proposed change acceptable since it clarifies that there are exceptions and therefore, provides a clear and objective application of the Cooper TS Required Actions and associated Completion Times and it adopts an approved TSTF-529 change to the Cooper TSs.
3.1.2 Proposed Changes to LCO 3.0.4 As stated in Section 2.2.4 of this SE, the current Cooper TS LCO 3.0.4 contains three options, (LCO 3.0.4.a, b, and c). LCO 3.0.4.a ends with a semicolon and LCO 3.0.4.b also ends with semicolon followed by the word or.
LCO 3.0.4.b states, in part, After performance of a risk assessment if appropriate; exceptions to this Specification are stated in the individual Specifications; or, could lead to operator misinterpretation. Operators could misapply this statement by believing the or applies to the phrase regarding exceptions and that LCO 3.0.4.a, b, and c apply concurrently.
The licensee proposed to clarify this sentence by placing the statement regarding exceptions in parentheses and deleting the first semicolon after appropriate. The proposed Cooper TS LCO 3.0.4 would state the following: After performance of a risk assessment if appropriate (exceptions to this Specification are stated in the individual Specifications); or.
The NRC staff finds that the change is editorial since it does not change the requirements currently in the TSs. The NRC staff approved placing the statement regarding exceptions in parentheses and replacing the ending comma with a semicolon in the STSs in TSTF-529.
However, for Cooper, the semicolon already exists in lieu of comma matching the STSs. The NRC staff finds the proposed change acceptable since it removes the potential for misapplication of LCO 3.0.4 allowances, and therefore, provides a clear and objective application of the Cooper TS Required Actions, and it adopts an approved TSTF-529 change to the Cooper TSs.
3.1.3 Proposed Changes to SR 3.0.3 The NRC has typically interpreted SR 3.0.3, which is quoted in Section 2.2.5 of this SE, as inapplicable to SRs that have never been previously performed. This is because the allowance provided by SR 3.0.3 is based on the fact that the SR was satisfactorily met in the past and the most probable result of performing the SR is the verification of conformance with the requirements. Therefore, there is reasonable expectation that the SR will be met when performed.
However, the NRC staff recognizes that there are instances in which an SR may not have been performed in the past, but there is still a reasonable expectation that the SR will be met when performed. As an example, an SR may require testing of a relay contact and the licensee discovers that the relay contact has never been tested as required in accordance with a particular SR. That licensee, however, may determine that there is a reasonable expectation that the SR will be met when performed because the subject relay contact has been tested by another SR or that operation of the subject relay contact has been successful in the past.
The delay period allowed by Cooper SR 3.0.3 offers adequate time to complete SRs that have been missed. In addition, this delay period permits the completion of an SR before complying with required actions or other remedial measures that might preclude completion of the SR.
The NRC staff finds the application of the delay period provided by Cooper SR 3.0.3 acceptable for use on SRs that have never been performed so as long as licensees can provide an adequate determination of reasonable expectation that the SR will be met when performed.
The licensee proposed adding a sentence to Cooper SR 3.0.3 as described in Section 2.2.5 of this SE. The NRC staff approved adding the sentence to STS SR 3.0.3 in TSTF-529. When making a determination of reasonable expectation that the SR will be met when performed, the licensees should consider many factors. These factors include, but are not limited to, things such as the period of time since the SR was last performed; or whether the SR, or a portion thereof, has ever been performed; and many other indications, tests, or activities that might support the expectation that the SR will be met when performed. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation an SR will be met when performed should increase based on the length of time since the last performance of the SR. If the SR has been performed recently, a review of the SR history and equipment performance may be sufficient to support a reasonable expectation that the SR will be met when performed. For SRs that have not been performed for a long period of time or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is capable of performing its specified safety function(s). The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.
The proposed TS change, which expands the scope of SR 3.0.3 to SRs that have never been performed, is acceptable because it requires the licensee to make an adequate determination of a reasonable expectation the SR will be met when performed. In addition, the proposed change augments plant safety because it could prevent unnecessary plant shutdowns by providing adequate time to complete SRs that have never been performed but are likely to achieve satisfactory results. Finally, the addition of the sentence adopts an approved TSTF-529 change to the Cooper TSs.
3.2 Summary As described in Section 2.3 of this SE, the regulations contained in 10 CFR 50.36 require that TSs include items in specified categories, including LCOs and SRs. The proposed changes modify the use and application of Completion Times, LCO applicability, and SR applicability by adopting changes approved by the NRC staff in TSTF-529, Revision 4. The Cooper TSs continue to specify the LCOs and specify the remedial measures to be taken if one of these requirements is not satisfied. The TSs continue to specify the appropriate SRs to ensure that the necessary quality of affected structures, systems and components are maintained.
Therefore, the NRC staff finds that the proposed changes to the LCOs and SRs as noted above are acceptable because the TSs, as amended, will continue to meet 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3), respectively.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Nebraska State official was notified of the proposed issuance of the amendment on October 6, 2020. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.
The NRC 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 as published in the Federal Register on June 30, 2020 (85 FR 39222), 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.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: J. Wilson, NRR Date: October 22, 2020
ML20282A176 (For TSTF-529, OGC review exempted). *by e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DSS/STSB/BC* NRR/DORL/LPL4/BC*
NAME TWengert (SLingam for) PBlechman VCusumano JDixon-Herrity DATE 10/19/2020 10/19/2020 9/9/2020 10/22/2020 OFFICE NRR/DORL/LPL4/PM*
NAME TWengert DATE 10/22/2020