NLS2021041, Request for Exception from Leak Testing Requirement of the Primary Containment Leakage Rate Testing Program

Request for Exception from Leak Testing Requirement of the Primary Containment Leakage Rate Testing Program

ML21202A200
Person / Time
Site:	Cooper
Issue date:	07/20/2021
From:	Dia K Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2021041
Download: ML21202A200 (19)

Text

H Nebraska Public Power District NLS2021041 July 20, 2021 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 "Always there when you need us" 50.90

Subject:

Request for Exception from Leak Testing Requirement of the Cooper Nuclear Station Primary Containment Leakage Rate Testing Program Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Pursuant to 10 CFR 50.90, Nebraska Public Power District (NPPD) is submitting a request for an amendment to the Cooper Nuclear Station (CNS) Technical Specifications (TS). The proposed license amendment request (LAR) would revise CNS TS, Section 5.5.12, "Primary Containment Leakage Rate Testing Program" to allow for an exception to a leak testing requirement of the program. Specifically, NPPD requests to extend the allowance to not vent and drain pathways during the Type A test, which have been Type B or C tested within the previous 24 calendar months of the Type A test, from 24 calendar months to 30 calendar months.

NPPD requests approval of the proposed LAR by July 20, 2022, to support Refuel Outage RE32 (Fall of 2022). The amendment will be implemented within 60 days of approval. provides NPPD's evaluation of the proposed TS change. Attachment 2 provides the proposed changes to the current CNS TS on marked-up pages. Attachment 3 provides the revised TS pages in final typed format. There are no associated TS Bases changes.

This proposed TS change has been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). NPPD has concluded that the proposed TS change does not involve a significant hazards consideration and satisfies the environmental consideration categorical exclusion criteria of 10 CFR 51.22( c )(9). This request is submitted under oath or affirmation pursuant to 10 CFR 50.30(b ).

By copy of this letter and its attachments, the appropriate State of Nebraska official is notified in accordance with 10 CFR 50.91(b)(l). Copies are also being provided to the Nuclear Regulatory Commission (NRC) Region IV office and the CNS Resident Inspector in accordance with 10 CFR 50.4(b)(l).

Should you have any questions or require additional information, please contact Linda Dewhirst, Regulatory Affairs and Compliance Manager, at ( 402) 825-5416.

COOPER NUCLEAR STATION 72676 648A Ave I P.O. Box 98 / Brownville, NE 68321 http://www.nppd.com

NLS2021041 Page 2 of2 I declare under penalty of perjury that the foregoing is true and correct.

Executed On: 7 /JD t :)...c:>21 Dale Sincerely, Khalil Dia.

General Manager of Plant Operations

/dv Attachments: 1. Request for Exception from Leak Testing Requirement

2. Proposed Technical Specifications Change (Mark-Up)

3. Revised Technical Specifications Pages cc:

Regional Administrator w/attachments USNRC - Region IV Cooper Project Manager w/attachments USNRC - NRR Plant Licensing Branch IV Senior Resident Inspector w/attachments USNRC-CNS Nebraska Health and Human Services w/attachments Department of Regulation and Licensure NPG Distribution w/attachments CNS Records w/attachments

NLS2021041 Page 1 of9 1.0 2.0 3.0 4.0 5.0 Request for Exception from Leak Testing Requirement Cooper Nuclear Station, Docket 50-298, License No. DPR-46 Summary Description Proposed Change

Reason for Request

Background Technical Evaluation 5.1 Conclusion 6.0 Regulatory Evaluation 6.1 No Significant Hazards Consideration Analysis 6.2 Conclusion 7.0 Environmental Consideration 8.0 Reference

NLS2021041 Page 2 of9 1.0

SUMMARY

DESCRIPTION The proposed license amendment would revise Cooper Nuclear Station (CNS) Technical Specifications (TS) Section 5.5.12, "Primary Containment Leakage Rate Testing Program," to include an exception to the 24 calendar month interval exclusion of certain pathways during Type A testing. Specifically, Nebraska Public Power District (NPPD) requests to extend the allowance to not vent and drain pathways during the Type A test, which have been Type B or C tested within the previous 24 calendar months of the Type A test, from 24 calendar months to 30 calendar months.

2.0 PROPOSED CHANGE

CNS TS Section 5.5.12, "Primary Containment Leakage Rate Testing Program," currently states:

"A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September, 1995, as modified by the following exceptions:

1. Exemption from Appendix J to 1 0CFR Part 50 to allow reverse direction local leak rate testing of four containment isolation valves at Cooper Nuclear Station (TAC NO. M89769) (July 22, 1994).

2. Exemption from Appendix J to 1 0CFR Part 50 to allow MSIV testing at 29 psig and expansion bellows testing at 5 psig between the plies (Sept. 16, 1977).

3. Exception to NEI 94-01, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Section 9.2.3: The first Type A test performed after the December 7, 1998 Type A test shall be performed no later than December 7, 2013.

4. Exemption from Section III.A of 1 0CFR Part 50, Appendix J, Option B, to allow the leakage contribution from Main Steam Pathway (Main Steam lines and Main Steam inboard drain line) leakage to be excluded from the overall integrated leakage rate from Type A tests (September 14, 2009).

5. Exemption from Section 111.B of 1 0CFR Part 50, Appendix J, Option B, to allow the contribution from Main Steam Pathway (Main Steam lines and Main Steam inboard drain line) leakage to be excluded from the sum of the leakage rates from Type Band Type C tests (September 14, 2009).

6. Exception to NEI 94-01, "Industry Guideline from Implementing Performance-Based Option of 10 CFR 50, Appendix J," to allow testing of Type C Residual Heat Removal heat exchanger relief valves and their associated Type B testable

NLS2021041 Page 3 of9 discharge flange tests at the same frequency as the visual examination, seat leakage testing, and set pressure testing performed for these valves under the requirements of the Inservice Testing Program per 10 CFR 50.55a(f)."

The proposed change would add a seventh exemption/exception to TS 5.5.12. Specifically, the added exception would state:

7. Exception to NEI 94-01, Revision 0, "Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J", Section 8.0 and Section 9.2.1, to allow that pathways which are Type B or C tested within the previous 30 calendar months of the Type A test need not be vented or drained during the Type A test.

There are no associated TS Bases changes.

3.0 REASON FOR REQUEST NEI 94-01, Revision 0, contains an allowance that for planning and scheduling purposes, or ALARA considerations, pathways which are Type B or C tested within the previous 24 calendar months need not be vented or drained during the Type A test. The as-found and as-left leakage rates from those tests are added to the Type A results. The 24 calendar month criterion was appropriate at the time NEI 94-01, Revision 0, was approved because most plants were operating on an 18 month refueling cycle. The 24 calendar months allowed the use of leak test results from the previous refueling outage. Since that time, plants have progressed to 24 month refueling cycles causing the benefit of this allowance to be greatly reduced. Allowing pathways that have been Type B or C tested within the previous 30 calendar months to not be vented or drained during the Type A test would restore this benefit, reducing outage resources and radiological dose.

4.0 BACKGROUND

The testing requirements of 10 CFR 50, Appendix J, provide assurance that leakage from the containment, including systems and components that penetrate the containment, does not exceed the allowable leakage values specified in the TS. Appendix J also ensures that periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment and the systems and components penetrating primary containment. The limitation on containment leakage provides assurance that the containment would perform its design function following an accident up to and including the plant design basis accident.

Appendix J identifies three types of required tests: (1) Type A tests, intended to measure the primary containment overall integrated leakage rate; (2) Type B tests, intended to detect local leaks and to measure leakage across pressure-containing or leakage limiting boundaries ( other than valves) for primary containment penetrations, and; (3) Type C tests, intended to measure containment isolation valve leakage rates. Type B and C tests identify the vast majority of potential containment leakage paths. Type A tests identify the overall (integrated) containment leakage rate and serve to ensure continued leakage integrity of the containment structure by

NLS2021041 Page 4 of9 evaluating those structural parts of the containment not covered by Type B and C testing.

10 CFR Part 50, Appendix J, was revised, effective October 26, 1995, to allow licensees to choose containment leakage testing under either Option A, "Prescriptive Requirements," or Option B, "Performance-Based Requirements." Option B requires that test intervals for Type A, Type B, and Type C testing be determined by using a performance-based approach.

Performance-based test intervals are based on consideration of the operating history of the component and resulting risk from its failure. The use of the term "performance-based" in 10 CFR 50, Appendix J refers to both the performance history necessary to extend test intervals as well as to the criteria necessary to meet the requirements of Option B.

CNS Operating License Amendment No. 180, dated March 3, 2000 (Reference), approved the implementation of 10 CFR Part 50, Appendix J, Option B. The amendment added TS section 5.5.12, "Primary Containment Leakage Rate Testing Program," to require Type A, Band C testing in accordance with Regulatory Guide (RG) 1.163 "Performance-Based Containment Leak-Test Program," dated September 1995. RG 1.163 specifies a method acceptable to the Nuclear Regulatory Commission (NRC) for complying with Option B by approving the use of NEI 94-01, Revision 0, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," and American Nuclear Standards Institute/ American Nuclear Society Standard ANSI/ ANS - 56.8-1994.

The adoption of the Option B performance-based containment leakage rate testing program altered the frequency of measuring primary containment leakage in Type A, B, and C tests but did not alter the basic method by which Appendix J leakage rate testing is performed. The frequency is based on an evaluation of the 'as found' leakage history to determine a frequency for leakage testing which provides assurance that leakage limits will not be exceeded. The changes to the Type B and Type C test frequency allowed by Option B result in a minimal increase in containment leakage.

5.0 TECHNICAL EVALUATION

CNS License Amendment No. 180 approved implementation of 10 CFR Part 50, Appendix J, Option B, by adding TS 5.5.12 to require Type A, B, and C testing in accordance with RG 1.163, dated September 1995. RG 1.163 endorses the methodology for complying with Option B identified in NEI 94-01, Revision 0. Under Option B, test intervals for Type A, Type B, and Type C testing may be determined by using a performance-based approach. Performance-based test intervals are based on consideration of operating history of the component and resulting risk from its failure. Performance-based for Appendix J refers to both the performance history necessary to extend test intervals as well as the criteria necessary to meet the requirements of Option B. The extended frequency interval for testing allowed by NEI 94-01 is based upon a generic evaluation documented in NUREG-1493, "Performance-Based Containment Leak-Test Program." NUREG-1493 found the effect of Type Band Type C testing on overall accident risk is small and concluded that:

Performance-based alternatives to local leakage rate testing requirements are feasible without significant risk impacts; and Although extended testing intervals led to minor increases in potential off-site dose consequences, the actual decrease in on-site (worker) doses exceeded (by at least an order of magnitude) the potential off-site dose increases.

NLS2021041 Page 5 of9 As identified in NEI 94-01, Revision 0, Step 10.2.1.1 and 10.2.3.1, Type Band Type C tests shall be performed prior to initial reactor operation and subsequent periodic Type B and Type C tests shall be performed at a frequency of at least once per 3 0 months, until adequate performance has been established consistent with Sections 10.2.1.2 and 10.2.3.2. The surveillance frequency for Type B and C testing may be increased based upon completion of two consecutive periodic As-found Type B or Type C tests where results of each test are within a licensee's allowable administrative limits. Elapsed time between the first and last tests in a series of consecutive satisfactory tests used to determine performance shall be 24 months or the nominal test interval ( e.g. refueling cycle) for the component prior to implementing Option B to Appendix J. An extended test interval for Type B or C tests may be increased to a specific value in a range of frequencies from greater than once per 30 months up to a maximum of once per 120 months for Type B and 60 months for Type C. The specific test interval for Type B or C penetrations should be determined by a licensee in accordance with Section 11.0.

CNS is currently required to follow NEI 94-01, Revision 0. This document states the following:

For planning and scheduling purposes, or ALARA considerations, pathways which are Type B or C tested within the previous 24 calendar months need not be vented or drained during the Type A test. [section 8. 0, Testing Methodologies for Type A, B, and C Tests}.

The As-Found and the As-left leakage rate for all pathway's that are not drained and vented must be determined by Type B and Type C testing within the previous 2 4 calendar months of the time that the Type A test is performed and must be added to the Type A leakage rate UCL to determine the overall La surveillance acceptance criteria.....

[section 8.0, Testing Methodologies for Type A, B, and C Tests and 9.2.1, Pretest Inspection and Test Methodology}.

CNS is currently on a 24-month refueling cycle. Most Appendix J Type B and Type C tests are performed during refueling outages, with a select few Type B and Type C tests performed pre-outage if the online scheduling risk supports it. CNS plans to perform a Type A test toward the end of refueling outage RE32 scheduled during the Fall of 2022. The Type Band C testing that is not on an extended frequency under Option B will be tested during RE32 (or pre-outage).

These Type B and Type C tests will meet the 24 calendar month requirement of NEI 94-01, Revision 0. However, any type Band C testing on an extended frequency that was tested during the previous refueling outage (RE31) in the Fall of 2020 (or pre-outage), would not meet the 24 calendar month requirement ofNEI 94-01, Revision 0. The time period would be approximately 24-26 months prior to the Type A test. Therefore, without this exception, CNS would have to re-perform the Type Band Type C tests performed during RE3 l in RE32 to be in compliance with the 24 calendar month criteria. The Type Band C tests that would require re-performance are only those on an extended frequency per NEI 94-01, Revision 0, based on their good performance history. This involves approximately seventy-eight (78) Type B and C tests; forty-one ( 41) of which are Type B and thirty-seven (3 7) of which are Type C. These tests would result in additional scheduling concerns, resources required, and approximately three hundred (300) mrem of radiological dose during RE32 without a compensating increase in safety. The

NLS2021041 Page 6 of9 NEI 94-01, Revision 0, 24 month exclusion period has not historically been an issue at CNS, as the last Type A test was performed in 2012, when CNS was on an 18-month refueling cycle.

5.1 Conclusion NPPD requests that the pathways which are Type B and Type C tested within the previous 30 calendar months need not be vented or drained during the Type A test. This revision is a permanent exception from the 24-month interval requirement of NEI 94-01, Revision 0, Sections 8.0 and 9.2.1.

The Type B and Type C tests performed during RE3 l on extended testing frequencies have demonstrated the leak-tightness of their associated penetrations and maintain containment integrity as required. The exception being requested does not impact the criteria or performance expectations for the extended test frequencies of these Type B and C tests. Test frequency extensions will otherwise continue to be determined using the guidelines ofNEI 94-01, Revision 0. Therefore, allowing the 24 calendar month exclusion for Type B and Type C tested penetrations to extend beyond the 24 calendar month period (up to a 30 calendar month period) will have a negligible impact on containment integrity and will allow continued implementation of an effective testing strategy for these penetrations. Additionally, subsequent revisions ofNEI 94-01 have revised the Type A test standard exclusion period for previously performed Type Band Type C tests to this same 30 calendar month period.

6.0 REGULATORY EVALUATION

License Amendment 180 authorized NPPD to use 10 CPR 50, Appendix J, Option B provisions for Type A, Type B, and Type C tests, and provided TS 5.5.12 which requires a program to establish the leakage rate testing of the Primary Containment as required by 10 CPR 50.54( o) and 10 CPR 50, Appendix J, Option B, as modified by approved exemptions. This program must be in accordance with the guidelines in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, as modified by exceptions. Four previously approved exemptions and two exceptions for CNS are identified as sub-paragraphs 1 through 6 of TS 5.5.12.a.

Under Appendix J, Option B, "Performance-Based Requirements,"Section V.B.3, the regulatory guide or other implementation document used by a licensee to develop a performance-based leakage-testing program must be included, by general reference, in the plant technical specifications. The CNS Technical Specifications, Section 5.5.12, "Primary Containment Leakage Rate Testing Program," states that this program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995. The Regulatory Guide references NEI 94-01, Revision 0, as providing methods acceptable to the NRC staff for complying with the provisions of Option B in Appendix J to 10 CPR Part 50.

NEI 94-01, Revision 0, Section 8.0 states, "For planning and scheduling purposes, or ALARA considerations, pathways which are Type B or C tested within the previous 24 calendar months

NLS2021041 Page 7 of9 need not be vented or drained during the Type A test." Section 8.0 and Section 9.2.1 state, "The As-found and the As-left leakage rate for all pathways that are not drained and vented must be determined by Type B and Type C testing within the previous 24 calendar months of the time that the Type A test is performed and must be added to the Type A leakage rate UCL to determine the overall La surveillance acceptance criteria in accordance with the definition in ANSI/ANS 56.8-1994."

Subsequent revisions 2-A and 3-A ofNEI 94-01, replaced the 24 calendar month requirement in these sections with 30 calendar months. In the NRC generic safety evaluation for revisions 2-A and 3-A, no limitations were placed on Section 8.0 by the NRC. The use of revisions 2-A and 3-A, and the 3 0 calendar month requirement has been approved for use by numerous nuclear facilities.

CNS was designed and constructed to meet the principle design criteria described in the Atomic Energy Commission's (AEC) proposed rule, "General Design Criteria [GDC] for Nuclear Power Plant Construction Permits," published in the Federal Register on July 11, 1967 (32 FR 10213).

The degree of conformance to the 1967 proposed GDC is described in Appendix F, "Conformance to AEC Proposed General Design Criteria" to the Updated Safety Analysis Report (USAR) for CNS. The applicable criteria in Appendix F for the proposed change are Criterion 54, "Containment Leakage Rate Testing," Criterion 55, "Containment Periodic Leakage Rate Testing," Criterion 56, "Provisions for Testing of Penetrations," and Criterion 57, "Provisions for Testing oflsolation Valves." The proposed change does not affect conformance with any of the criteria as described in the USAR.

6.1 No Significant Hazards Consideration Analysis Nebraska Public Power District (NPPD) has requested the Nuclear Regulatory Commission to amend Renewed Facility Operating License DPR-46 for Cooper Nuclear Station to revise Technical Specifications (TS) 5.5.12, "Primary Containment Leak Rate Testing Program." It is requested that an exception to NEI 94-01, Revision 0, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J,"

be approved to extend the allowance to not vent and drain pathways during the Type A test which have been Type B or C tested within the previous 24 calendar months of the Type A test, from 24 calendar months to 30 calendar months.

NPPD has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

NLS2021041 Page 8 of9 The proposed change extends the interval allowance of 24 calendar months to 30 calendar months, for pathways that have been recently Type B or C tested. The primary containment function is to provide an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment for postulated accidents. The proposed amendment does not involve a physical change to the plant or a change in the manner in which the plant is operated or controlled. The proposed amendment does not change the leak rate criteria that Updated Safety Analysis Report Chapter XIV accident analyses are based on. The testing requirements to periodically demonstrate the integrity of containment exist to ensure the plant's ability to mitigate the consequences of an accident and do not involve any accident precursors or initiators.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change extends the interval allowance of 24 calendar months to 30 calendar months, for pathways that have been recently Type B or C tested. The testing requirements to periodically demonstrate the integrity of the containment exist to ensure the plant's ability to mitigate the consequences of an accident and do not involve any accident precursors or initiators. The proposed change does not involve physical change to the plant (i.e., no new or different type of equipment will be installed) or a change to the manner in which the plant is operated or controlled.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change extends the interval allowance of 24 calendar months to 30 calendar months, for pathways that have been recently Type B or C tested. The change does not affect plant operations, design functions, or any analysis that verifies the capability of a structure, system, or component of the plant to perform a design function. This change does not affect safety limits, limiting safety system setpoints, or limiting conditions for operation.

NLS2021041 Page 9 of9 The specific requirements and conditions of the TS Containment Leakage Rate Testing Program exist to ensure that the degree of containment structural integrity and leak-tightness that is considered in the plant safety analysis is maintained.

The overall containment leak rate limit specified by the TS is maintained. The design, operation, testing methods and acceptance criteria for Type A, B, and C containment leakage tests specified in applicable codes and standards would continue to be met with the acceptance of this proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NPPD concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92( c ), and, accordingly, a finding of "no significant hazards consideration" is justified.

6.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's 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.

7.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22( c )(9). Therefore, pursuant to 10 CFR 5 l.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

8.0 REFERENCE Letter from Lawrence J. Burkhart, USNRC Project Directorate IV, to J. H. Swailes, NPPD, dated March 3, 2000, "Cooper Nuclear Station - Issuance of Amendment RE: Changes to the Technical Specifications (TSs) to Implement 10 CFR Part 50, Appendix J, Option B, and Changes to the TS Associated with the Containment Air Lock Interlock Mechanism, Isolation Valve Time Testing, and Credit for Administrative Means for Securing Isolation Devices (TAC NO.

MA6877)" (ML003690276).

NLS2021041 Page 1 of 4 Proposed Technical Specifications Change (Mark-Up)

Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Pages 5.0-17 Pages 5.0-18 and 5.0-19 included due to shifting of text from page 5.0-17.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program ( continued)

5.

6.

7.

Exemption from Section II1.B of 1 0CFR Part 50, Appendix J, Option B, to allow the contribution from Main Steam Pathway (Main Steam lines and Main Steam inboard drain line) leakage to be excluded from the sum of the leakage rates from Type B and Type C tests (September 14, 2009).

Exception to NEI 94-01, "Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J," to allow testing of Type C Residual Heat Removal heat exchanger relief valves and their associated Type B testable discharge flange tests at the same frequency as the visual examination, seat leakage testing, and set pressure testing performed for these valves under the requirements of the lnservice Testing Program per 10 CFR 50.55a(f).

Exception to NEI 94-01, Rev. 0, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Section 8.0 and Section 9.2.1. to allow that pathways which are Type B or C tested within the previous 30 calendar months of the Type A test. need not be vented or drained during the Type A test.

b.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 58.0 psig. The containment design pressure is 56.0 psig.

c.

The maximum allowable containment leakage rate, La, at Pa, shall be 0.635% of containment air weight per day.

d.

Leakage Rate acceptance criteria are:

1.

Containment leakage rate acceptance criterion is s 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are, <0.60 La for the Type B and C tests and s 0. 75 La for Type A tests.

2.

Air lock testing acceptance criteria are:

a.

Overall air lock leakage rate is s 12 scfh when tested at ~ Pa.

b.

Overall air lock leakage rate is s 0.23 scfh when tested at~ 3.0 psig.

e.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

f.

The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

Cooper 5.0-17

~-)

(continued)

Amendment No.

5.5 Programs and Manuals (continued) 5.5.13 Control Room Envelope Habitability Program Programs and Manuals 5.5 A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Filter (CREF) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (OBA) conditions without personnel receiving radiation exposures in excess of either (a) 5 rem whole body or its equivalent to any part of the body for the duration of the loss-of-coolant accident, or (b) 5 rem total effective dose equivalent (TEDE) for the duration of the fuel handling accident. The program shall include the following elements:

a.

The definition of the CRE and CRE boundary.

b.

Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c.

Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors,"

Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. No exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0, are proposed.

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by the CREF System, operating at the flow rate required by the Ventilation Filter Testing Program, at a Frequency of 24 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

Cooper 5.0-18 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Room Envelope Habitability Program (continued}

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered air inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.14 Surveillance Frequency Control Program Cooper This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.0-19 Amendment No.

NLS2021041 Page 1 of 4 Revised Technical Specifications Pages Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Pages 5.0-17 Pages 5.0-18 and 5.0-19 included due to shifting of text from page 5.0-17.

5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)

Programs and Manuals 5.5

5.

Exemption from Section II1.B of 10CFR Part 50, Appendix J, Option B, to allow the contribution from Main Steam Pathway (Main Steam lines and Main Steam inboard drain line) leakage to be excluded from the sum of the leakage rates from Type B and Type C tests (September 14, 2009).

6.

Exception to NEI 94-01, "Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J," to allow testing of Type C Residual Heat Removal heat exchanger relief valves and their associated Type B testable discharge flange tests at the same frequency as the visual examination, seat leakage testing, and set pressure testing performed for these valves under the requirements of the lnservice Testing Program per 10 CFR 50.55a(f).

7.

Exception to NEI 94-01, Rev. 0, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Section 8.0 and Section 9.2.1, to allow that pathways which are Type B or C tested within the previous 30 calendar months of the Type A test, need not be vented or drained during the Type A test.

b.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 58.0 psig. The containment design pressure is 56.0 psig.

c.

The maximum allowable containment leakage rate, La, at Pa, shall be 0.635% of containment air weight per day.

d.

Leakage Rate acceptance criteria are:

1.

Containment leakage rate acceptance criterion is :5 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are, <0.60 La for the Type B and C tests and

5 0. 75 La for Type A tests.

2.

Air lock testing acceptance criteria are:

a.

Overall air lock leakage rate is :s; 12 scfh when tested at~ Pa.

b.

Overall air lock leakage rate is :s; 0.23 scfh when tested at~ 3.0 psig.

e.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

f.

The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

Cooper 5.0-17

( continued)

Amendment No.

5.5 Programs and Manuals (continued) 5.5.13 Control Room Envelope Habitability Program Programs and Manuals 5.5 A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Filter (CREF) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (OBA) conditions without personnel receiving radiation exposures in excess of either (a) 5 rem whole body or its equivalent to any part of the body for the duration of the loss-of-coolant accident, or (b) 5 rem total effective dose equivalent (TEDE) for the duration of the fuel handling accident. The program shall include the following elements:

a.

The definition of the CRE and CRE boundary.

b.

Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c.

Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors,"

Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. No exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0, are proposed.

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by the CREF System, operating at the flow rate required by the Ventilation Filter Testing Program, at a Frequency of 24 months. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

( continued)

Cooper 5.0-18 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Room Envelope Habitability Program ( continued)

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered air inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.14 Surveillance Frequency Control Program Cooper This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.0-19 Amendment No.