NLS2006042, License Amendment Request for Revision of Technical Specification 3.10.1, Inservice Leak and Hydrostatic Testing Operation

License Amendment Request for Revision of Technical Specification 3.10.1, Inservice Leak and Hydrostatic Testing Operation

ML061710087
Person / Time
Site:	Cooper
Issue date:	06/16/2006
From:	Edington R Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2006042
Download: ML061710087 (25)

Text

N Nebraska Public Power District Always there when you need us 50.90 NLS2006042 June 16, 2006 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

License Amendment Request for Revision of Technical Specification 3.10.1, Inservice Leak and Hydrostatic Testing Operation Cooper Nuclear Station, Docket No. 50-298, DPR-46 The purpose of this letter is for the Nebraska Public Power District (NPPD) to request an amendment to Facility Operating License DPR-46 in accordance with the provisions of 10 CFR 50.4 and 10 CFR 50.90 to revise the Cooper Nuclear Station (CNS) Technical Specifications (TS). The license amendment request (LAR) is to revise TS Section 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," to allow performance of control rod scram time testing initiated in conjunction with the performance of an inservice leak or hydrostatic test. provides a description of the TS changes, the basis for the amendment, the no significant hazards consideration evaluation pursuant to 10 CFR 50.91 (a)(1), and the environmental impact evaluation pursuant to 10 CFR 51.22. Attachment 2 provides the proposed changes to the current CNS TS on marked up pages. Attachment 3 provides the proposed changes in final typed format. Attachment 4 provides conforming changes to the TS Bases for NRC information.

This LAR is based on Technical Specification Task Force (TSTF) Traveler TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities." Since this TSTF traveler is currently under review by the Nuclear Regulatory Commission (NRC) and not yet approved, the changes to TS that are ultimately approved through the TSTF traveler may differ from those issued for CNS. If the TS changes in the NRC-approved TSTF-484 differ from the TS changes issued by amendment to the CNS operating license, NPPD will submit a LAR to revise the CNS TS to be consistent with the TS in the approved TSTF traveler as necessary.

NPPD requests NRC approval of the proposed TS changes and issuance of the requested license amendment by October 14, 2006. CNS is scheduled to shutdown to begin the Cycle 23 refueling outage the third week of October. Control rod scram time testing is required prior to exceeding 40 percent rated thermal power by TS Surveillance Requirement 3.1.4.4. Leak COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2006042 Page 2 of 3 testing of the reactor pressure vessel is required following reassembly and prior to startup. This license amendment will allow control rod scram time testing to be performed in conjunction with that leak testing. This expedited review period has been discussed with the NRC Project Manager. The amendment will be implemented within 30 days following issuance.

These proposed TS changes have been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). Amendments to the CNS Facility Operating License through Amendment 221, issued May 2, 2006, have been incorporated into this request. 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)(1). Copies to the NRC Region IV office and the CNS Resident Inspector are also being provided in accordance with 10 CFR 50.4(b)(1).

Should you have any questions concerning this matter, please contact Paul Fleming, Licensing Manager, at (402) 825-2774.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 6 Sincerely, Randall K. Edington Vice President - Nuclear and Chief Nuclear Officer

/rr Attachments cc: Regional Administrator w/attachments USNRC - Region IV Cooper Project Manager w/attachments USNRC - NRR Project Directorate IV-]

Senior Resident Inspector w/attachments USNRC-CNS

NLS2006042 Page 3 of 3 Nebraska Health and Human Services W/ attachments Department of Regulation and Licensure NPG Distribution w/o attachments CNS Records w/attachments

NLS2006042 Attachment I Page 1 of 10 Attachment I NPPD Evaluation License Amendment Request for Revision of Technical Specification 3.10.1, Inservice Leak and Hydrostatic Testing Operation Cooper Nuclear Station, Docket 50-298, DPR-46 Revised Technical Specification Page 3.10-1 1.0 Description 2.0 Proposed Changes 3.0 Background 4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements Criteria 6.0 Environmental Consideration 7.0 References

NLS2006042 Attachment I Page 2 of 10 1.0 Description This proposed amendment would revise Cooper Nuclear Station (CNS) Technical Specification (TS) Section 3.10.1, "Inservice Leak and Hydrostatic Testing Operation,"

to allow the average reactor coolant system (RCS) temperature to exceed 212'F as a consequence of maintaining pressure during the inservice leak or hydrostatic testing, and to allow completion of control rod scram time testing initiated in conjunction with the inservice leak or hydrostatic test.

This change is based on Technical Specification Task Force (TSTF) traveler TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities," Rev. 0 (Reference 2). That TSTF is currently under review by the Nuclear Regulatory Commission (NRC) Staff.

This change is needed to support the conduct of Operating Cycle 23 refueling outage, scheduled to begin the third week of October, 2006. This change would allow the required control rod scram time testing to be conducted in a safer and more efficient manner.

2.0 Proposed Changes The current Limiting Condition for Operation (LCO) 3.10.1 allows the average RCS temperature to exceed the Mode 3 threshold value of 212°F specified in TS Table 1.1-1, "MODES," while continuing to consider the plant as remaining in Mode 4 solely to allow performance of inservice leak or hydrostatic test, provided certain secondary containment operability requirements, specified in LCO 3.10.1, are imposed consistent with operation in MODE 3.

The proposed change to LCO 3.10.1, and the associated Bases, would extend the scope to include provisions for temperature increases above 212°F as a consequence of inservice leak or hydrostatic testing, and as a consequence of control rod scram time testing initiated in conjunction with the inservice leak test or hydrostatic test, when initial test conditions are below 212°F. Bases changes are also proposed to describe the activities and allowances for parallel activities during these evolutions.

The revised LCO 3.10.1 states that the average RCS temperature specified in TS Table 1.1-1 for Mode 4 may be changed to ,NA," and operation considered not to be in Mode 3, and the requirements of LCO 3.4.8 may be suspended to allow reactor coolant temperature > 212'F:

• For performance of an inservice leak or hydrostatic test,

" As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or.

• As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

NLS2006042 Attachment I Page 3 of 10 Conforming changes to the TS Bases, consistent with those proposed in TSTF-484, will be made pursuant to 10 CFR 50.59 and in accordance with TS 5.5.10, TS Bases Control Program, as part of amendment implementation following issuance of the amendment.

The following is a description of the Bases changes that will be made.

1. The first paragraph of the BACKGROUND section discusses the purpose of LCO 3.10.1. That paragraph is amended by adding an allowance to complete the pressure tests when the initial conditions do not require temperatures greater than 212'F, and to continue performing control rod scram time testing when the testing is initiated in conjunction with the inservice leak or hydrostatic test.

2. The third paragraph of the BACKGROUND section discusses increases in the minimum allowable vessel temperature as a result of increases in vessel fluence over time. This paragraph is amended by adding a discussion that maintaining RCS temperatures within a small band during the test can be impractical, how heat removal is controlled, and that tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable.

3. A new fourth paragraph is added to the BACKGROUND section to discuss the pressure required for control rod scram time tests and the approximate pressure required for performing the hydrostatic and/or leakage tests.

4. A new fifth paragraph is added to the BACKGROUND section to state that other testing, Excess Flow Check Valve testing for example, may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

5. The APPLICABLE SAFETY ANALYSES section is amended by a discussion that the reactor coolant temperature may be greater than 212'F during or as a consequence of hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

6. The LCO subsection is amended by adding a paragraph stating that RCS temperatures may drift above 212'F during the hydrostatic or leak test, or during subsequent control rod scram time testing even if the required minimum temperature was less than 212TF. The new paragraph also notes that performance of other tests and inspections is not precluded when in LCO 3.10.1.

7. The APPLICABILITY section is revised to clarify that the Mode 4 requirements may be modified as a consequence of the inservice leak or hydrostatic tests, or as a consequence of control rod scram time testing initiated in conjunction with the leak or hydrostatic test.

NLS2006042 Attachment I Page 4 of 10 Markups of the TS Bases showing the proposed revisions are provided for information in Attachment 4.

3.0 Background The current LCO 3.10.1 allows the plant to be considered in Mode 4 during the performance of inservice leak or hydrostatic tests when RCS temperature exceeds 212'F. It does this by specifying that the temperature for Mode 4 in TS Table 1.1-1, "MODES," may be changed to "not applicable." This avoids the need to perform the testing required by the surveillance requirements for the systems that are required to be operable when in Mode 3.

Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requires inservice hydrostatic testing and system leakage pressure tests on the reactor pressure vessel (RPV). Hydrostatic tests are required to be performed once every ten years and leakage tests are required to be performed each refueling outage prior to the reactor core achieving critical operation.

The minimum temperatures at the pressure required by the ASME Code are determined from the limits specified in CNS TS LCO 3.4.9, "Reactor Coolant System (RCS)

Pressure and Temperature (P/T) Limits." A near-water solid RPV, with heat added by operation of the recirculation pumps and the presence of decay heat, is used to achieve the pressure and temperature required for these tests.

The leakage or hydrostatic tests are started after the required pressure is achieved, with the temperature increased as required by LCO 3.4.9. During performance of these tests the RCS temperature will continue to increase as a result of recirculation pump operation and core decay heat. Because these tests are performed near the end of a refueling outage, the core decay heat is relatively low, (i.e., it is significantly lower than that present immediately following shutdown). However, because the RPV is closed, and the Residual Heat Removal (RHR) Shutdown Cooling (SDC) isolated, the recirculation pump operation and core decay heat will cause the average RCS temperature to increase. It is therefore possible that RCS temperature will exceed the Mode 3 threshold temperature of 212'F during the performance of these tests.

4.0 Technical Analysis The existing provisions of CNS LCO 3.10.1 allow the average RCS temperature to exceed 212°F if required to perform hydrostatic and leak tests while continuing to consider the plant to be in Mode 4. The proposed change will extend the allowance to include operations where the test commenced at RCS temperature below 212'F, but exceeded 212°F as a consequence of maintaining adequate pressure required for inservice leak and hydrostatic testing before completion of the testing. Without this extension of the allowance the testing would have to be terminated if average RCS

NLS2006042 Page 5 of 10 temperature exceeded 212'F during the conduct of the test. This will allow completion of testing without the potential for interrupting the test in order to reduce reactor vessel pressure, cool the RCS, and restart the test at a temperature below 212'F. Since the current LCO 3.10.1 allows testing to be conducted when RCS temperatures are required to be above 212'F to begin the testing, the proposed change does not introduce any new operational conditions beyond those allowed by the current LCO 3.10.1.

LCO 3.10.1 requires that secondary containment and standby gas treatment system be operable and capable of handling any airborne radioactivity or steam leaks that could occur during performance of hydrostatic or leak testing. These requirements will conservatively limit radiation releases to the environment in the event of a release of radioactivity from the RCS. No changes are proposed to these requirements as part of the proposed new provisions.

Since the tests are performed with the RPV nearly water solid, at low decay heat values, and near Mode 4 conditions, the stored energy in the reactor core will be very low.

Under these conditions, the potential for failed fuel and subsequent increase in coolant activity above the limits of LCO 3.4.6, "RCS Specific Activity," are minimized. Small leaks from the RCS would be detected by inspections before a significant loss of inventory occurred. Two low pressure emergency core cooling systems (ECCS) injection/spray subsystems are required to be operable in Mode 4 by CNS TS 3.5.2, "ECCS - Shutdown." In the event of a large RCS leak the RPV would rapidly depressurize and allow operation of the low pressure ECCS. The capability of the low pressure ECCS would be adequate to maintain the fuel covered under the low decay heat conditions during these tests.

CNS TS Surveillance Requirement (SR) 3.1.4.1 and SR 3.1.4.4 require that control rod scram time be tested with reactor steam dome pressure greater than 800 psig before exceeding 40% rated thermal power (RTP). Performance of control rod scram time testing is typically scheduled concurrent with inservice leak or hydrostatic testing while RCS pressure is greater than 800 psig. Scram time testing is initiated at this time, but because of the number of control rods that must be tested, the testing typically cannot be completed prior to exceeding 212'F. In this event the scram time testing has to be terminated and restarted later during startup, typically above 25% RTP, and completed before exceeding 40% RTP. The proposed change will allow completion of scram time testing initiated during inservice leak or hydrostatic testing.

Extending the provisions of LCO 3.10.1 to allow performance of scram time testing concurrent with inservice leak or hydrostatic testing is safer and more efficient than performing this testing during power ascension after the reactor is critical. Because the reactor is shutdown during the leak or hydrostatic testing, individual control rods can be selected and withdrawn for scram time testing without reactivity concerns, such as shutdown margin, power shaping, etc. Performing scram time testing during power ascension requires use of the control rods for power shaping and controlling thermal limits as well as the scram timing. This can result in complications and a longer time

NLS2006042 Attachment I Page 6 of 10 spent performing scram timing. Thus, performing control rod scram time testing concurrent with the leak or hydrostatic testing is safer, quicker, and more efficient than performing scram time testing during startup, prior to exceeding 40% RTP.

The protection provided by the normally required Mode 4 applicable LCOs, in addition to the secondary containment requirements required to be met by LCO 3.10.1, ensures acceptable consequences in the event of any postulated abnormal event during normal hydrostatic test conditions. Extending the allowances of LCO 3.10.1 to this additional condition does not create any new modes of operation or operating conditions that are not currently allowed by LCO 3.10.1.

It is acceptable to perform other testing concurrent with the inservice leak or hydrostatic test provided that this testing can be performed safely and does not interfere with the leak or hydrostatic test. Testing of Excess Flow Check Valves required by SR 3.6.1.3.8 is one example of this testing. A statement that other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic test is added to TS 3.10.1 Bases. However, it is not permissible to remain in TS 3.10.1 solely to complete such testing following the completion of inservice leak or hydrostatic testing and scram time testing.

Following completion of the inservice leak or hydrostatic test and control rod scram time testing, the RPV is depressurized and the RCS cooled to less than 212'F, thereby taking the plant back to Mode 4, Cold Shutdown. Ascending to Mode 3 as part of startup will require satisfactory performance of the TS surveillance requirements on structures, systems, and components that are required to be operable in Mode 3.

Discussion of Precedents TSTF-484, Rev. 0, "Use of TS 3.10.1 for Scram Time Testing Activities," is not yet approved for licensee adoption. For that reason the NRC has not issued any license amendment adopting the TSTF. By letter dated March 1, 2006 (Reference 1), FPL Energy Duane Arnold, LLC, submitted a license amendment request to adopt TSTF-484 at Duane Arnold Energy Center (DAEC) as a pilot.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration 10 CFR 50.91 (a)(1) requires that licensees provide to the Nuclear Regulatory Commission an evaluation of no significant hazard posed by issuance of the amendment, using the standards of 10 CFR 50.92 at the time it requests an amendment of the operating license. Nebraska Public Power District (NPPD) has evaluated this proposed amendment with respect to the criteria given in 10 CFR 50.92(c). The following is the evaluation required by 10 CFR 50.91(a)(]).

NLS2006042 Page 7 of 10 NPPD is requesting an amendment of the operating license for the Cooper Nuclear Station (CNS). The current Limiting Condition for Operation (LCO) in Technical Specification (TS) Section 3.10.1, "Inservice Leak and Hydrostatic Testing Operation," allows inservice leak and hydrostatic testing to be performed with average reactor coolant system (RCS) temperature exceeding the operating Mode 3 threshold temperature of 212°F while continuing to consider the plant to be in operating Mode 4. The revised LCO 3.10.1 would extend the allowance to allow completion of control rod scram time testing initiated in conjunction with the inservice leak and hydrostatic testing, and to allow application of LCO 3.10.1 to leak or hydrostatic testing that was initiated at RCS temperature less than 212'F.

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Current TS LCO 3.10.1 allows average RCS temperature to exceed 212 0F when required during the conduct of hydrostatic and inservice leak tests without requiring entry into plant operating Mode 3, Hot Shutdown.

Extending this allowance to testing in which average RCS temperature exceeds 212°F as a consequence of maintaining pressure and to the performance of scram time testing that is initiated in conjunction with the hydrostatic and inservice leak tests will not impact any accident initiator. Thus, the proposed change does not affect the probability of any accident.

The proposed changes do not involve any modification of equipment used to mitigate accidents, and do not impact any system used in the mitigation of design basis accidents. The proposed changes do not involve modified operation of equipment or system used to mitigate accidents. Thus, the proposed changes do not affect the consequences of an accident.

Based on the above, NPPD concludes that the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

.2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed TS revisions to TS LCO 3.10.1 do not involve physical modification of the plant or a change in plant operation. The proposed

NLS2006042 Page 8 of 10 TS revisions do not revise or eliminate any existing requirements, and do not impose any additional requirements. The proposed changes do not alter assumptions made in the safety analysis, and are consistent with the safety analysis assumptions and current plant operating practice.

Allowing the performance of control rod scram time testing, while in plant operating Mode 4 with average RCS temperature greater than 212'F, does not create the possibility of a different kind of accident.

Based on the above NPPD concludes that these proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No.

The proposed changes do not impact the design or operation of the Reactor Protection System or the Emergency Core Cooling System.

Allowing completion of scram time testing that was initiated in conjunction with inservice leak or hydrostatic testing prior to reactor criticality and startup will eliminate the need for unnecessary plant maneuvers to control reactor temperature and pressure, thereby resulting in enhanced safe operation.

Based on the above, NPPD concludes that these proposed changes do not involve a significant reduction in a margin of safety.

Based on the responses to the above questions, 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.

5.2 Applicable Regulatory Requirements/Criteria The design criteria for CNS are specified in the Updated Safety Analysis Report (USAR) Appendix F, Conformance to AEC Design Criteria. Criterion 36, "Reactor Coolant Pressure Boundary Surveillance," is the one criterion applicable to the proposed change. The following is the criterion and a discussion of how it is satisfied by the current design as presented in the USAR.

Criterion 36: Reactor Coolant Pressure Boundary Surveillance "Reactorcoolantpressure boundary components shall have provisionsfor inspection, testing, and surveillance by appropriatemeans to assess the

NLS2006042 Page 9 of 10 structuraland leak-tight integrity of the boundary components during their service lifetime. For the reactorvessel, a materialsurveillanceprogram conforming with ASTM-E-185-66 shall be provided."

Extensive quality control assurance programs were followed during the entire fabrication of the reactor coolant system. The reactor coolant system was given a final hydrostatic test at 1563 psig in accordance with code requirements prior to initial reactor startup. Inservice inspections are performed in accordance with ASME Section XI. The system is checked for leaks, and abnormal conditions are corrected before reactor startup. The minimum vessel temperature during hydrostatic tests is at least 60'F above the calculated NDTT [nil ductility transition temperature] prior to pressurizing the vessel. Vessel material surveillance samples are used to enable periodic monitoring of material properties with exposure. The program includes specimens of the base metal, heat affected zone metal and standards specimens. Also, leakage from the reactor coolant system is monitored during reactor operation, in accordance with Technical Specifications. The material surveillance program conforms to BWRVIP-86-A, October 2002.

The proposed change to LCO 3.10.1 will not invalidate the basis for how the above criterion is satisfied. Therefore, the above criterion will continue to be satisfied with the requested changes. Furthermore, the proposed change does not change the design requirements or the assumptions in the safety analysis.

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.

6.0 Environmental Consideration 10 CFR 51.22 provides criteria for, and identification of, licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment or environmental impact statement. 10 CFR 51.22(c)(9) identifies an amendment to an operating license for a reactor which changes an inspection or a surveillance requirement as a categorical exclusion provided that operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amount of any effluents that may be released off-site, or (3) result in a significant increase in individual or cumulative occupational radiation exposure.

CNS review has determined that the proposed amendment, which would change an inspection or surveillance requirement, does not involve (1) a significant hazards

NLS2006042 Page 10 of 10 consideration, (2) a significant change in the types or significant increase in the amounts of any effluent that might be released offsite, or (3) 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 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 References

1. Letter from Gary Van Middlesworth, Vice President, Duane Arnold Energy Center, to U.S. Nuclear Regulatory Commission, dated March 1, 2006,

Subject:

Technical Specification Change Request (TSCR-078): Adoption of TSTF-484, Rev. 0, "Use of TS 3.10.1 for Scram Time Testing Activities."

2. TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities," Rev. 0.

NLS2006042 Page I of 2 Attachment 2 Proposed Technical Specification Revisions (Mark up)

Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown," may be suspended, to allow ra-ctor coolant perfor.ance of an in,,ryicc leak or hydr....atio testte.wpq,.,jvre provided the following MODE 3 LCOs are met: > zJZ*0:;

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," Functions I and 3 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

C. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)"; and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

+-

4r_ APPLICABILITY: MODE 4 with average reactor coolant temperature > 212°F.

" o efrmneo n inservc eko yrsai et

" As a consequence of maintaining adequate pressure for an inservice x leak or hydrostatic test, or

- . As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, Cooper 3.10-1 Amendment No.I4

NLS2006042 Page 1 of 2 Attachment 3 Proposed Technical Specification Revisions (Final Typed)

Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown," may be suspended, to allow reactor coolant temperature >212°F:

• For performance of an inservice leak or hydrostatic test,

• As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation,"

Functions 1 and 3 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)";

and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212°F.

Cooper 3.10-1 Amendment No.

NLS2006042 Page I of 7 Attachment 4 Proposed Technical Specification Bases Revisions (Information Only)

Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46 Revised Technical Specification Bases Pages B 3.10-1 B 3.10-3 NOTE: No revisions are proposed to Bases pages B 3.10-2, B 3.10-4, and B 3.10-5.

These pages are provided only for completeness of the Bases section.

NLS2006042 Attachment 4 Page 2 of 7 Bases Inserts INSERT 1 or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 212'F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212'F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.

INSERT 2 However, even with required minimum reactor coolant temperatures < 212°F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor steam dome pressure > 800 psig. The hydrostatic and/or RCS leakage tests require pressure of approximately 1,000 psig.

Other testing (Excess Flow Check Valve testing for example) may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

INSERT 3 Additionally, even with required minimum reactor coolant temperatures < 212 0 F, RCS temperatures may drift above 212°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 212"F (normally corresponding to MODE 3).

Inservice hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation, decay heat and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits."

These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure.

Periodic updates to the RPV P/T limit curves are performed as necessary, based upon the results of analyses of irradiated surveillance specimens removed from the vessel.

Hydrostatic and leak testing may eventually b re uired with minimum reactor coolant temperature > 212"F.'2 I

APPLICABLE Allowi the reactor to be considered in MODE 4'dnainw

-SAFETY. ANA -yostat or. e tes 'n when the reactor coolant era ure is > e ectively provides an exception to

-MODE 3requirements, including OPERABILITY of primary containment and the full complement-of redundant Emergency Core Cooling Systems. Since the s or -k tests 1.*  !

are performed nearly water solid, at low decay heat values, during or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram lime testing initiated in conjunction with an inservice leak or hydrostatic test, (continued)

Cooper B 3.10-1 Revision 0

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE and near MODE 4 conditions, the stored energy in the SAFETY ANALYSES reactor core will be very low. Under these conditions, the (continued) potential for failed fuel and a subsequent increase in coolant activity above the LCO 3.4.6, "RCS Specific Activity," limits are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.

In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, "ECCS--Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36 (c)(2)(ii) (Ref. 3) apply. Special Operations LCOs provide flexibility to perform-certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation at reactor coolant (continued)

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Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO temperatures > 212°F can be in accordance with Table 1.1-1 (continued) for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures -

> 212°F, while performance of inservice leak and hydrostatic testing results in the inope ubsystems required when > 212°F (i.e., MODE I.

If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of and for control rod scram LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cool ing limne testing initiated in System-Cold Shutdown." The additional requirements for conjunction with an secondary containment LCOs to be met will provide sufficient inservice leak protection for operations at reactoi- coolant temperatures hydrostatic test. > 212*F for the purpose of performing Ei )an inservice leak or hydrostatic test I.

This LCO allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirementtat) in efect m

• .,a~ .r ately " to immedjaely 2 fter thfoperatoeain n.

APPLICABILITY The MODE 4 requirements may only be modified for thee Vperformance oinservice leak or hydrostatic tests o that these operations Can be considered as in MODE 4, even though the reactor coolant temperature is > 212"F. The additional I requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur.

Operations in all other MODES are unaffected by this LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to I

inservice leak and hydrostatic testing operation.

Section 1.3, Completion Times, specifies that 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.

7-3 (continued)

Cooper B 3.10-3 Revision 0 or as a consequence of control rod scram time testing initiated in conjunction wilt an inservice leak or hvdrostatic test.

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES ACTIONS Section 1.3 also specifies that Required Actions of the (continued) Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.

A.1 If an LCO specified in LCO 3.10.1 is not met, the ACTIONS applicable to the stated requirements are entered immediately and complied with. Required Action A.1 has been modified by a Note that clarifies the intent of another LCO's Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to < 212°F.

A.2.] and A.2.2 Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.1 to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO's Applicability. Activities that could further increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to < 212"F with normal cooldown procedures. The Completion Time is also consistent with the time provided in LCO 3.0.3 to reach MODE 4 from MODE 3.

SURVEILLANCE SR 3.10.1.1 REQUIREMENTS The LCOs made applicable are required to have their

'Surveillances met to establish that this LCO is being met.

A discussion of the applicable SRs is provided in their respective Bases.

(continued)

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Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES (continued)

REFERENCES ]. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.

2. USAR, Section XIV-6.5.

3. 10 CFR 50.36(c)(2)(ii).

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I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© Correspondence Number: NLS2006042 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE If the TS changes in the NRC-approved TSTF-484 differ from the TS changes issued 90 days following by amendment to the CNS operating NRC approval of license, NPPD will submit a license NLS2006042-01 TSTF-484 amendment request to revise the CNS TS to be consistent with the TS in the approved TSTF traveler as necessary.

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