NLS2009034, Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process

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Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process
ML091560032
Person / Time
Site: Cooper Entergy icon.png
Issue date: 06/02/2009
From: Minahan S
Nebraska Public Power District (NPPD)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2009034
Download: ML091560032 (22)
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Text

N Nebraska Public Power District

'Always there when you need us" 50.90 NLS2009034 June 2, 2009 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process Cooper Nuclear Station, Docket No. 50-298, DPR-46

Reference:

Federal Register Notice 72 FR 63935, published November 13, 2007, Notice of Availability of Model Application Concerning Technical Specification Improvement to Revise Control Rod Notch Surveillance Frequency, Clarify SRM Insert Control Rod Action, and Clarify Frequency Example

Dear Sir or Madam:

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 proposed amendment would: (1) delete TS Surveillance Requirement (SR) 3.1.3.2 and revise SR 3.1.3.3 in TS 3.1.3, "Control Rod OPERABILITY", and (2) revise Example 1.4-3 in Section 1.4 "Frequency" to clarify the applicability of the 1.25 surveillance test interval extension consistent with the model application in the Reference. 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 in marked up format. Attachment 3 provides the final typed TS pages to be issued with the amendment. Attachment 4 provides a summary of the regulatory commitments made in this submittal. Attachment 5 provides conforming changes to the TS Bases for Nuclear Regulatory Commission (NRC) information.

NPPD requests approval of the proposed amendment by May 31, 2010. Once approved, the amendment will be implemented within 60 days.

This proposed TS change has 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 232 issued March 20, 2009, have been incorporated into this request.

P.O. Box 98 / Brownville, NE 68321-0098 Telephone:COOPER NUCLEAR/ Fax: (402) 825-52117 (402) 825-3811 STATION www,.nppd.com A~oI

NLS2009034 Page 2 of 2 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 are also being provided to the NRC Region IV office and the CNS Senior Resident Inspector in accordance with 10 CFR 50.4(b)(1).

Should you have any questions concerning this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.

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

Executed onj iC. , . O-0 0 (Date)

Sincerely, Stewart B. Minahan Vice President - Nuclear and Chief Nuclear Officer

/em Attachments

1. Descriptionand Assessment
2. Proposed Technical Specifications Changes
3. Revised Technical Specification Pages
4. Regulatory Commitments
5. Proposed Technical Specification Bases Changes cc: Regional Administrator w/attachments USNRC - Region IV Cooper Project Manager w/attachments USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/attachments USNRC - CNS Nebraska Health and Human Services w/ attachments.

Department of Regulation and Licensure NPG Distribution w/o attachments CNS Records w/attachments

NLS2009034 Page 1 of 3 Attachment 1 Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process Cooper Nuclear Station, NRC Docket 50-298, DPR-46 1.0 Description 2.0 Assessment 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations 3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination 3.2 Verification and Commitments 4.0 Environmental Evaluation

NLS2009034 Page 2 of 3 Attachment 1 Description and Assessment Cooper Nuclear Station, NRC Docket 50-298, DPR-46 1.0 Description The proposed amendment would: (1) delete Technical Specification (TS) Surveillance Requirement (SR) 3.1.3.2 and revise SR 3.1.3.3 in TS 3.1.3, "Control Rod OPERABILITY", and (2) revise Example 1.4-3 in Section 1.4 "Frequency" to clarify the applicability of the 1.25 surveillance test interval extension.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard TS change TSTF-475-A, Revision 1. The Federal Register Notice, published on November 13, 2007, announced the availability of this TS improvement through the consolidated line item improvement process (CLIIP).

2.0 Assessment 2.1 Applicability of Published Safety Evaluation Nebraska Public Power District (NPPD) has reviewed the safety evaluation dated November 13, 2007, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-475-A, Revision 1. NPPD has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Cooper Nuclear Station (CNS) and justify this amendment for the incorporation of the changes to CNS TS.

2.2 Optional Changes and Variations NPPD is proposing two variations from the TS changes described in TSTF-475-A, Revision 1. The first variation is to reflect not renumbering the remaining SRs after deleting SR 3.1.3.2. This eliminates the need to revise Table 3.1.4-1. The second variation is in the Bases for SR 3.1.3.3 to reflect just the single SR 3.1.3.3 and to apply the potential power reduction basis to all withdrawn control rods rather than just those partially withdrawn. This conforms the Bases to the SR.

NLS2009034 Page 3 of 3 3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination NPPD has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

NPPD has concluded that the proposed NSHCD presented in the Federal Register Notice is applicable to CNS and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on November 13, 2007, for this TS improvement, NPPD verifies the applicability of TSTF-475-A to CNS, and commits to establishing Technical Specification Bases as proposed in TSTF-475-A, Revision 1, with the variations noted.

These changes are based on TSTF change traveler TSTF-475-A, Revision 1, that proposes revisions to the Standard TS by: (1) Revising the frequency of SR 3.1.3.2, notch testing of fully withdrawn control rod, from 7 days after the control rod is withdrawn and THERMAL POWER is greater than the Low Power Setpoint (LPSP) of the Rod Worth Minimizer (RWM) to 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM, and (2) revising Example 1.4-3 in Section 1.4, "Frequency," to clarify that the 1.25 surveillance test interval extension in SR 3.0.2 is applicable to time periods discussed in NOTES in the "SURVEILLANCE" column in addition to the time periods in the "FREQUENCY" column.

4.0 Environmental Evaluation NPPD has reviewed the environmental evaluation included in the model safety evaluation dated November 13, 2007, as part of the CLIIP. NPPD has concluded that the staff's findings presented in that evaluation are applicable to CNS and the evaluation is hereby incorporated by reference for this application.

NLS2009034 Page 1 of 5 Attachment 2 Proposed Technical Specification Revisions (Markup)

Cooper Nuclear Station, Docket No. 50-298, DPR-46 Revised Technical Specification Pages 1.4-4 1.4-5 3.1-8 3.1-10

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-2 (continued)

"Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If reactor power decreases to < 25% RTP, the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.

EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

NOTE--------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after > 25% RTP.

Perform channel adjustment. 7 days The interval continues whether or not the unit operation is

< 25% RTP between performances.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches > 25% RTP to perform the Surveillance. The Surveillance is still considered to be within the "specified Frequency." Therefore, if the Surveillance were not performed within the 7 day interval (plus the extension allowed by SR 3.0.2), but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power > 25% RTP.

(continued)

Cooper 1.4-4 Amendment No. 178

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued) SK lovI-S Once the unit reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be lallowed for completing the Surveillance. If the Surveillance wee ot performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval there wou d then eb a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

EXAMPLE 1.4-4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

-- NOTE ------------------

Only required to be met in MODE 1.

Verify leakage rates are within limits. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1.4-4 specifies that the requirements of this Surveillance do not have to be met until the unit is in MODE 1. The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance.

Therefore, if the Surveillance were not performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval (plus the extension allowed by SR 3.0.2),

but the unit was not in MODE 1, there would be no failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing MODES, even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency exceeded, provided the MODE change was not made into MODE 1. Prior to entering MODE I (assuming again that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency were not met), SR 3.0.4 would require satisfying the SR.

Cooper 1.4-5 Amendment No. 178

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 3-92--

Perform &P 3.v 1.R 2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from SR 3.1.3.3 for discovery of each withdrawn Condition A OPERABLE control rod. concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM.

AND A.4 Perform SR 3.1.1.1. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Two or more withdrawn 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 /> control rods stuck.

C., One or more control C.1 ---------NOTE ---------

rods inoperable for RWM may be bypassed reasoýs: other than as allowed by CoidTti-on A or B. LCO 3.3.2.1, if required, to allow insertion of inoperable control rod and continued operation.

Fully insert 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> inoperable control rod.

AND C.2 Disarm the associated 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CRD.

(continued)

Cooper 3.1-8 Amendment No. 178

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.1.3.2

(- kteý'

ýýyJS SR 3.1.3.3------------------ NOTE--------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each lall withdrawn control rod 31 days at least one notch.

SR 3.1.3.4 Verify each control rod scram time from In accordance fully withdrawn to notch position 06 is with

< 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 (continued)

Cooper 3.1-10 Amendment No.

NLS2009034 Page 1 of 5 Attachment 3 Proposed Technical Specification Revisions (Final Typed)

Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46 Technical Specification Pages 1.4-4 1.4-5 3.1-8 3.1-10

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-2 (continued)

"Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If reactor power decreases to < 25% RTP, the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.

EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

NOTE--------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after

> 25% RTP.

Perform channel adjustment. 7 days The interval continues whether or not the unit operation is < 25% RTP between performances.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches > 25% RTP to perform the Surveillance.

The Surveillance is still considered to be within the "specified Frequency."

Therefore, if the Surveillance were not performed within the 7 day interval (plus the extension allowed by SR 3.0.2), but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO.

Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (plus the extension allowed by SR 3.0.2) with power

> 25% RTP.

(continued)

Cooper 1.4-4 Amendment No.

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)

Once the unit reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance. If the Surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval (plus the extension allowed by SR 3.0.2), there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

EXAMPLE 1.4-4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

NOTE ----------------------------

Only required to be met in MODE 1.

Verify leakage rates are within limits. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1.4-4 specifies that the requirements of this Surveillance do not have to be met until the unit is in MODE 1. The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance. Therefore, if the Surveillance were not performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval (plus the extension allowed by SR 3.0.2), but the unit was not in MODE 1, there would be no failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing MODES, even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency exceeded, provided the MODE change was not made into MODE 1. Prior to entering MODE 1 (assuming again that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency were not met), SR 3.0.4 would require satisfying the SR.

Cooper 1.4-5 Amendment No.

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Perform SR 3.1.3.3 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from each withdrawn discovery of OPERABLE control rod. Condition A

.concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM.

AND A.4 Perform SR 3.1.1.1. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Two or more withdrawn 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 /> control rods stuck.

C. One or more control rods C.1 ----------- NOTE------

inoperable for reasons RWM may be bypassed other than Condition A as allowed by or B. LCO 3.3.2.1, if required, to allow insertion of inoperable control rod and continued operation.

Fully insert inoperable 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> control rod.

AND C.2 Disarm the associated 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CRD.

(continued)

Cooper 3.1-8 Amendment No.

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.1.3.2 (Deleted)

SR 3.1.3.3 --------------------- NOTE----------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod at least one notch. 31 days SR 3.1.3.4 Verify each control rod scram time from fully In accordance withdrawn to notch position 06 is < 7 seconds. with SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 (continued)

Cooper 3.1-10 Amendment No.

NLS2009034 Page 1 of 1 Attachment 4 Regulatory Commitments Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46 The following table identifies those actions committed to by Nebraska Public Power District in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to David Van Der Kamp, Licensing Manager.

REGULATORY COMMITMENT DUE DATE Nebraska Public Power District will establish the Technical Specification Bases changes for TS B 3.1.3 consistent with those Implementation of shown in TSTF-475-A, Reyision 1, "Control Rod Notch Testing License Amendment Frequency and SRM Insert Control Rod Action", with the variations noted.

NLS2009034 Page 1 of 5 Attachment 5 Proposed Technical Specification Bases Changes Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46 Technical Specification Bases Pages B 3.1-15 B 3.1-16 B 3.1-19 B 3.1-20

('Jo ./

r9f;~c~AJ ~jsEA~~ Control Rod OPERABILITY EaJ"&-J-~(C5 \AA-A6- CATt,ý /10-TlfOAJ- B 3.1.3 (ON. ~~PAG&-ý0 ) O9C I A44 TF6 BASES APPLICABILITY In MODES I and 2, the control rods are assumed to function during a DBA or transient and are therefore. required to be OPERABLE in these MODES. In MODES'3 and 4, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod OPERABILITY during these conditions. Control rod requirements in MODE 5 are located in LCO 3.9.5, "Control Rod OPERABILITY - Refueling."

ACTIONS The ACTIONS Table is modified by a Note indicating that a separate Condition entry is allowed for each control rod. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable control rod. Complying with the Required Actions may allow for continued operation, and subsequent inoperable control rods are governed by subsequent Condition entry and application of associated Required Actions.

A.1. A.2, A.3, and A.4 A control rod is considered stuck if it will not insert by either CRD drive water or scram pressure. With a fully inserted control rod stuck, no actions are required as long as the control rod remains fully inserted.

The Required Actions are modified by a Note, which allows the rod worth minimizer (RWM) to be bypassed if required to allow continued operation.

LCO 3.3.2.1, "Control Rod Block Instrumentation," provides additional requirements when the RWM is bypassed to ensure compliance with the CRDA analysis. With one withdrawn control rod stuck, the local scram

., reactivity rate'assumptions may not be met ifthe stuck control rod separation criteria are not met. Therefore, a verification that the separation criteria are met must be performed immediately. The separation criteria are not met if a) the stuck control rod occupies a location adjacent to two "slow" control rods, b) the stuck control rod occupies a location adjacent to one "slow" control rod, and the one "slow" control rod is also adjacent to another "slow" control rod; or c) if the stuck control rod occupies a location adjacent to one "stow" control rod when there is another pair of "slow" control rods adjacent to one another.

('continued)

(continued)

Cooper 133.1-15 June 10, 1999 I

Control Rod OPERABILITY B 3.1.3 BASES ACTIONS A.1. A.2, A.3, and A.4 (continued).

The description of "slow" control rods is provided in LCO 3.1.4, "Control Rod Scram Times." In addition, the associated control rod drive must be disarmed (hydraulically) in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The allowed Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is acceptable, considering the reactor can still be shut down, assuming no additional control. rods fail to insert, and provides a reasonable time to perform the Required Action in an orderly manner.

The control rod must be isolated from both scram and normal insert and withdraw pressure. Isolating the control rod from scram and normal insert and withdraw pressure prevents damage to the CRDM. The control rod should be isolated from scram and normal insert and withdraw pressure, while maintaining cooling water to the CRD.

Monitoring of the insertion capability of each withdrawn control rod must also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of Condition A concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM. SR 3.1.3.3 performs periodic tests of the control ro i se ion capability of withdrawn control rods. Testing each withdrawn control rod ensures that a generic problem does not exist. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock". The Required Action A.3 Completion Time only begins upon discovery of Condition A concurrent with THERMAL POWER greater than the actual LPSP of the RWM since the notch insertions may not be compatible with the requirements of rod pattern control (LCO 3.1.6) and the RWM (LCO 3.3.2.1). The allowed Completion Time provides a reasonable time to test the control rods, considering the potential for a need to reduce power to perform the tests.

To allow continued operation with a withdrawn control.rod stuck, an evaluation of adequate SDM is also required within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Should a DBA or transient require a shutdown, to preserve the single failure criterion, an additional control rod would have to be assumed to fail to insert when required. Therefore, the original SDM demonstration may not be valid. The SDM must therefore be evaluated (by rneasurement or analysis) with the stuck control rod at its stuck position and the highest worth OPERABLE control rod assumed to be fully withdrawn.

(continued)

Cooper B 3.1-16 , June 10, 1999 1

Control Rod OPERABILITY

-. B 3.1.3 BASES ACTIONS E.1 (continued) active function (i.e., scram) of the control rods. The number of control rods permitted to be inoperable when operating above 10% RTP (e.g., no CRDA considerations) could be more than the value specified, but the occurrence of a large number of inoperable control rods could be indicative of a generic problem, and investigation and resolution of the potential problem should be undertaken. The allowed Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.1.3.1 REQUIREMENTS The position of each control rod must be determined to ensure adequate information on control rod position is available to the operator for determining control rod OPERABILITY and controlling rod patterns. Control rod position may be determined by the use of OPERABLE position indicators, by moving control rods to a position with an OPERABLE indicator, or by the use of other appropriate methods. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency of this SR is based on operating experience related to expected changes in control rod position and the availability of control rod position indications in the control room Z _ n *.2 -

J._.i..? SR 3.1.3.3 Control rod insertion capability is demonstrated by inserting each partially or fully withdrawn control rod at least one notch and observing that the control rod moves.

The control rod may then be returned to its original position. This ensures the control rod is not stuck and is Thi free to insert on a scram signal.

  • S-urveillancef &r4i-G not required when THERMAL POWER is -ess-han or equal to the actual LPSP of the RWM, since the notch insertions may not be compatible with the requirements of the Banked Position Withdrawal Sequence BPWS LCO 3.1.6 and the RWM SR 3.1.3.)is base (counedof onprt x erltd- h changes *CRD / I (continued)

Cooper B 3.1-19 Revision 0

Control Rod OPERABILITY B 3.1.3 BASES SURVEILLANCE §I7IISR SR 3.1.3.3 (continued)

REQUIREMENTS L rods are tested at a 31 day Frequency, based on the potential power reduction required to allow the control rod movemen.and cons i rn ng S-9-,,*032 . [Furthermorei the 31 day r-equ-ency takes- into*

account operating experi.ence related to changes in CRD performance. At any time, if a control rod is immovable, a determination of that control rod's capability of insertion by scram (OPERABILITY) must be made and appropriate action taken.

ThW SRsa modified byVNote-. that allows$

31 days ' after withdrawal of the control rod and increasing power to above the LPSP, to perform the Surveillance. This acknowledges that the control rod must be first withdrawn and THERMAL POWER must be increased to above the LPSP before performance of the Surveillance, and therefore the Notes avoid potential conflicts with SR 3.0.3 and SR 3.0.4.

SR 3.1.3.4 Verifying that the scram time for each control rod to notch position 06 is < 7 seconds provides reasonable assurance that the controT rod will insert when required during a DBA or transient, thereby completing its shutdown. function.

This SR is performed in conjunction with the control rod scram time testing of SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.1.1, "Reactor Protection System (RPS)

Instrumentation," and the functional testing of SDV vent and drain valve.s in LCO 3.1.8, "Scram Discharge Volume (SDV)

Vent and Drain Valves," overlap this Surveillance to provide complete testing of the assumed safety function. The associated Frequencies are acceptable, considering the more frequent testing performed to demonstrate other aspects of control rod OPERABILITY and operating experience, which shows scram times do not significantly change over an operating cycle.

(continued)

Cooper B 3.1-20 Revision 0

4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©4 Correspondence Number: NLS2009034 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 Nebraska Public Power District will establish the Technical Specification Bases changes for TS Implementation of B3.1.3 consistent with those shown in TSTF-475-A, NLS2009034-01 License Amendment Revision 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action", with the variations noted.

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-4.- I 1~- I PROCEDURE 0.42 REVISION 23 PAGE 18 OF 26

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