NLS2010006, License Amendment Request to Correct Power Factor Limit and to Incorporate a Generic Revision in Technical Specification Surveillance Requirement 3.8.1.9

License Amendment Request to Correct Power Factor Limit and to Incorporate a Generic Revision in Technical Specification Surveillance Requirement 3.8.1.9

ML100610521
Person / Time
Site:	Cooper
Issue date:	02/25/2010
From:	Minahan S Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2010006
Download: ML100610521 (21)

Text

N Nebraska Public Power District "Always there when you need us" 50.90 NLS2010006 February 25, 2010 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

License Amendment Request to Correct Power Factor Limit and to Incorporate a Generic Revision in Technical Specification Surveillance Requirement 3.8.1.9 Nebraska Public Power District - Cooper Nuclear Station Docket No. 50-298, License No. DPR-46

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 revises TS Surveillance Requirement (SR) 3.8.1.9, Diesel Generator (DG) Load Test, to correct a non-conservative power factor (PF) value. In addition, this proposed change adds a new note to SR 3.8.1.9 consistent with Technical Specifications Task Force traveler TSTF-276-A Revision 2. This note allows the DG Load Test to be performed at the specified PF with clarifications addressing situations when the power factor cannot be achieved. NPPD has determined from the No Significant Hazards Consideration determination that this change does not involve a significant hazard.

NPPD requests approval of the proposed amendment by February 28, 2011 allowing for an approximate one-year Nuclear Regulatory Commission (NRC) review. Once approved, the amendment will be implemented within 60 days. 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 conforming changes to the TS Bases for NRC information.

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 COOPER NUCLEAR STATION Pt0. Box 98 / Brownville, NE 68321-0098 C1 1 Telephone: (402) 825-3811 / Fax: (402) 825-5217 wwwv.nppd corn

NLS2010006 Page 2 of 2 Facility Operating License through Amendment 235 issued October 25, 2009 have been incorporated into this request. This request is submitted under oath 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 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 ono2/3S"26/6O (Date)/

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

/em Attachments 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

NLS2010006 Page 1 of 10 License Amendment Request to Correct Power Factor Limit and to Incorporate a Generic Revision in Technical Specification Surveillance Requirement 3.8.1.9 Cooper Nuclear Station, Docket No. 50-298, DPR-46 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 3.1 Updated Safety Analysis Report (USAR) Safety Design Basis 3.2 Current TS Bases 3.3 New PF Limit 3.4 New Note to SR 3.8.1.9 4.0 Regulatory Safety Analysis 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions 5.0 Environmental Consideration 6.0 References

NLS2010006 Page 2 of 10 1.0

SUMMARY

DESCRIPTION This request is to amend Operating License DPR-46 for Cooper Nuclear Station (CNS).

This proposed change revises Technical Specification (TS) Surveillance Requirement (SR) 3.8.1.9, Diesel Generator (DG) Load Test, to correct a non-conservative power factor (PF) value. It also adds a new Note #3 from Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force Traveler TSTF-276-A, Revision 2, to allow the DG Load Test to be performed at the specified PF with clarifications addressing situations when the power factor cannot be achieved. The PF is relocated from the surveillance statement to the new note.

During activities in connection with Temporary Inspection (TI) 2515/176, Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing, CNS discovered the calculation for determining the plant electrical AC loads under various scenarios (NEDC 00-111) did not take into account worst case voltage and worst case frequency in determining maximum analyzed load on the DGs.

Furthermore, CNS determined the SR 3.8.1.9 value for PF limit of_< 0.9 was not conservative with respect to the range of calculated values in NEDC 00-111.

Subsequently, the surveillance procedures were placed on hold. The calculation was revised to incorporate worst case voltage and frequencies, and the surveillance procedures were ultimately revised to specify a more restrictive KVAR limit representing the new PF limit. The revised surveillance procedures satisfied the NRC Administrative Letter (AL) 98-10 expectation to implement administrative controls to compensate for the non-conservative TS during the time required to obtain a change to the TS.

The proposed addition of Note 3 to SR 3.8.1.9 in accordance with NRC approved TSTF-276-A, Revision 2, incorporates the generic relaxation on PF. TSTF-276-A, Revision 2, is incorporated in its entirety, except for deviations as noted in section 3.4 below.

CNS requests approval of this license amendment request by February 28, 2011, allowing for an approximate one-year NRC review. Upon receipt of the approved amendment, CNS will implement the change within 60 days. Pending issuance of the amendment, the following interim action is being taken in accordance with AL 98-10. The surveillance procedure has been revised to specify a more restrictive PF as a compensatory measure for the non-conservative TS.

2.0 DETAILED DESCRIPTION The following revisions are proposed for CNS TS.

2.1 Revise the surveillance statement in SR 3.8.1.9 to delete the phrase "operating at a power factor of< 0.9" in accordance with TSTF-276-A, Revision 2.

2.2 Add a new Note 3 in SR 3.8.1.9 in accordance with TSTF-276-A, Revision 2, to state, "If performed with DG synchronized with offsite power, the surveillance shall be

NLS2010006 Page 3 of 10 performed at a power factor < 0.89. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable."

Conforming changes to TS Bases pages are provided in Attachment 4 for NRC information, and will be made as an implementing action pursuant to TS 5.5.10, TS Bases Control Program, following issuance of the amendment. CNS includes in the Bases of SR 3.8.1.9 as Insert 1 a clarification that DG loadings less than 90% occurring during the first 10 seconds of accident loading are bounded by the test conditions of 90 - 100% accident load and are well within the generator capability curves. Insert 2 from TSTF-276-A, REVISION 2, explains that Note 3 ensures the DG is tested under load conditions that are as close to worst case design basis conditions as possible, but allows for those grid conditions where the PF cannot be maintained without adversely affecting emergency bus voltages or DG excitation.

3.0 TECHNICAL EVALUATION

3.1 Updated Safety Analysis Report (USAR) Safety Design Basis CNS is a boiling water reactor (BWR) of General Electric BWR4 'design, with Mark 1 containment. The Standby AC Power System at CNS consists of 2 independent, self-contained DG's independent of off-site power sources. Their purpose is to provide a single failure proof source of on-site AC power adequate for maintaining safe shutdown of the reactor following abnormal operational transients and postulated accidents. The generator sets have the ability to pick up loads as described in USAR Table VIII-5-1 in a sequence and time period described in Table VIII-5-2 to satisfy design basis loss-of-coolant accident (DBA LOCA) acceptance criteria assuming a loss of off-site power. Each DG has a continuous rated capacity of 4000 KW at a power factor of 0.8 with frequency at 60 Hz and voltage at 4,160 volts AC. The DGs are capable of being independently synchronized to normal, startup, and emergency station service transformers. This synchronization is performed manually for system performance tests or live source transfers. In the emergency mode, provisions exist to prevent: (a) automatic parallel electrical interconnection of both DGs and (b) automatic interconnection of either DG with station service transformers. The standby AC power system conforms to the applicable sections of "IEEE 308 Criteria for Class 1E Electrical Systems for Nuclear Power Generating Stations", issued in 1970.

3.2 Current TS Bases TS Bases B3.8.1 Safety Analysis notes that the initial conditions of DBAs and transient analyses in USAR Chapter VI and Chapter XIV assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC electrical power sources are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so the fuel, Reactor

NLS2010006 Page 4 of 10 Coolant System, and containment design limits are not exceeded. The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining the onsite or offsite AC sources OPERABLE during accident conditions in the event of: (a) an assumed loss of offsite power or onsite AC power; and (b) a worst case single failure. AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Bases for SR 3.8.1.9 notes the purpose of the surveillance is to demonstrate once every 18 months that the DG's can start and run continuously at full load capability for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Standard Technical Specification (STS) 3.8.1.14 specifies 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the DG endurance run, but during conversion to Improved Technical Specifications (ITS), CNS took exception to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> based on the requirements of IEEE Standard 387-1995, "IEEE Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations." Six hours of the test are to be at load equivalent to 90-100% of the continuous rating of the DG, and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the test are to be at a load equivalent to 105-110% of the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. Provisions for pre-lube and warm-up, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

To ensure the DG is tested under load conditions as close to design conditions as possible, testing must be performed using a PF of< 0.9. This PF was chosen to be representative of the actual design basis inductive loading the DG could experience.

A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG operability. Note 1 of SR 3.8.1.9 states that momentary transients due to changing bus loads do not invalidate this test.

Similarly, momentary PF transients above the limit do not invalidate the test.

3.3 New PF Limit The revised Calculation NEDC 00-111 determined the plant electrical AC loads under five evaluated scenarios and established the peak loading to be used for analyzing the CNS auxiliary power system. The calculated PF values for DG#1 and DG#2 over 11 time steps (0 seconds to 7 days) were greater than 0.89 except for the first time step for DG#2 (0 to 5 seconds). The calculation reflects accident loads sequencing onto the essential busses. During the first 10 seconds, DG loads are less than 90%. Since these loads are outside the surveillance test conditions, the corresponding PF's for those first two time steps are not applicable to testing DG endurance capability. Thus, a value of 0.89 was chosen as the PF limit that bounds expected DG PF values when loaded between 90% and 100% design basis accident loading.

NLS2010006 Page 5 of 10 3.4 New Note 3 to SR 3.8.1.9 When the DG is not paralleled to the grid, the power factor is determined by plant load and cannot be adjusted. Therefore, power factor requirements are applicable only when the test is performed with the DG paralleled to the grid. This change provides the allowance to proceed with the surveillance even if the specified power factor is not achieved. This change adds detail and is intended to improve clarity and ensure requirements are fully understood and consistently applied.

The rationale associated with NRC approved TSTF-276-A, Revision 2, applies to CNS. This TSTF modified STS (NUREG-1433) to allow certain DG testing to be performed even if the specified PF cannot be achieved. It revised STS section 3.8.1 to allow for an exception to meeting PF requirements when a DG is paralleled to the grid during surveillances. Under certain circumstances due to grid conditions, it may not always be possible to meet the specified power factor. Therefore, the TSTF modified STS SR 3.8.1.9, 3.8.1.10, and 3.8.1.14 notes to allow for the surveillances to proceed if the specified power factor requirement cannot be met. In these cases, the note requires that the power factor be maintained as close to the limit as possible.

The associated TS Bases for these SRs is revised to discuss this change as well.

TSTF-276-A, Revision 2, notes that when synchronized with offsite power, testing should be performed at a PF of< the specified limit. This PF is representative of the actual inductive loading a DG would see under design basis accident conditions.

Under certain conditions, however, Note 3 allows the surveillance to be conducted at a power factor other than < the limit. These conditions occur when grid voltage is high, and the additional field excitation needed to obtain a power factor < the limit results in voltages on the emergency busses that are too high. Under these conditions, the power factor should be maintained as close as practicable to the limit while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor < the limit may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to the limit without exceeding the DG excitation limits CNS has 2 deviations from the preapproved TSTF-276-A, Revision 2, because CNS does not have two of the SR's to which TSTF-276-A, Revision 2, applies. TSTF-276-A, Revision 2, applied to STS SR's 3.8.1.9, 3.8.1.10, and 3.8.1.14. During conversion to ITS CNS did not adopt Load Rejection SR's corresponding to STS SR 3.8.1.9 and SR 3.8.1.10, because they test a design feature that is not credited in the CNS accident analysis. So this note will only be added to the CNS SR corresponding to STS SR 3.8.1.14, i.e. CNS SR 3.8.1.9. Conforming Bases changes from TSTF-276-A, Revision 2, will be made as part of Amendment implementation.

NLS2010006 Page 6 of 10 4.0 REGULATORY SAFETY ANALYSIS 4.1 Applicable Regulatory Requirements/Criteria Construction of CNS predated the 1971 issuance of 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants." Appendix F, "Conformance to AEC Proposed General Design Criteria", of the USAR discusses that CNS is designed to conform to the proposed general design criteria (GDC) published in the July 11, 1967, Federal Register, except where commitments were made to specific 1971 GDC. It notes that the Atomic Energy Commission accepted CNS conformance with these proposed GDC.

The following is a discussion of the applicable regulations and the Draft GDC from USAR Appendix F, along with a discussion of continued conformance.

4.1.1 10 CFR 50.36, Technical Specifications 10 CFR 50.36(b) requires each license authorizing operation of a utilization facility to include TS. 10 CFR 50.36(d) specifies the categories that are to be included in TS. 10 CFR 50.36(d)(3) identifies Surveillance Requirements (SRs) as one of the categories to be included in TS. 10 CFR 50.36(d)(3) states:

"Surveillance Requirements are requirements relating to test, calibration, or inspection to assure the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and the limiting conditions for operation will be met."

The proposed change to SR 3.8.1.9 will continue to ensure that DG's are able to perform their safety related functions. Thus, the TS will continue to be met.

Therefore, CNS continues to meet this regulation with the proposed changes to TS SR's.

4.1.2 10 CFR 50, Appendix A, GDC 17, Electric Power Systems NOTE: The discussion of Criterion 24, "Emergency Power for Protection Systems" and Criterion 39, "Emergency Power for Engineered Safety Features" in CNS USAR Appendix F, states that NPPD is committed to 1971 GDC 17 which supersedes the draft GDC in their entirety. GDC 17 states the following:

"An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system

NLS2010006 Page 7 of 10 (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure."

This change does not affect CNS compliance with this GDC; CNS continues to comply with GDC 17.

4.2 Precedent The proposed change to SR 3.8.1.9 in this license amendment request is very similar to the Peach Bottom Atomic Power Station (PBAPS) request submitted June 24, 2004 to incorporate TSTF-276-A, Revision 2, submitted as part of a bulk TSTF submittal (Docket Nos. 05000277 and 05000278, ML052910355). NRC approved these requested changes under Amendment 259 to License DPR-44 and Amendment 262 to License DPR-56 dated May 10, 2006. Unlike PBAPS, CNS does not have Load Rejection SR's; so the new Note 3 would only be added to CNS SR 3.8.1.9.

4.3 No Significant Hazards Consideration 10 CFR 50.91 (a)(1) requires that licensee requests for operating license amendments be accompanied by an evaluation of no significant hazard posed by issuance of the amendment. 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)(1).

NPPD is requesting an amendment of the operating license for the Cooper Nuclear Station (CNS) that will revise Technical Specification (TS) Surveillance Requirement (SR) 3.8.1.9, Diesel Generator (DG) Load Test, to correct a non-conservative power factor (PF) value. It also adds a new Note #3 from NRC approved STS Task Force Traveler TSTF-276-A, Revision 2, to allow the DG Load Test to be performed at the specified PF with clarifications addressing situations when the power factor cannot be achieved. The PF is relocated from the surveillance statement to the new note.

NLS2010006 Page 8 of 10

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

Response: No.

Performing a surveillance that tests the DG is not a precursor of any accident previously evaluated. Revising the PF limit to be more conservative, and relaxing the requirement to maintain PF when paralleled to offsite power does not significantly affect the method of performing the surveillances such that the probability of an accident would be affected. These changes only affect surveillances of mitigative equipment and, therefore, do not have an impact on the probability of an accident previously evaluated.

Revising the surveillances by specifying a more conservative PF value ensures the DG's will provide the power assumed in calculations of design basis accident mitigation. Relaxing the requirement to maintain PF when paralleled to offsite power does not affect performance of the DG under accident conditions. The performance of the surveillances ensures that mitigative equipment is capable of performing its intended function, and therefore, the change does not involve a significant increase in the consequences of an accident previously evaluated.

Therefore, 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.

No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed changes. The systems, structures, and components previously required for the mitigation of a transient remain capable of fulfilling their intended design functions. The proposed changes have no adverse effects on a safety-related system or component and do not challenge the performance or integrity of safety related systems. As such, it does not introduce a mechanism for initiating a new or different accident than those described in the USAR.

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

NLS2010006 Page 9 of 10

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

Response: No.

The proposed changes will continue to ensure the DGs are able to perform their design function as assumed in calculations that evaluate their function during design basis accidents. Decreasing the PF limit for testing will not affect the design or functioning of the DGs. The increased reactive loading required to maintain the PF below the limit is small and well within DG capability. Based on this, the ability of CNS to mitigate the design basis accidents that rely on operation of the DG's is not adversely impacted. Revising the PF increases the margin of safety by specifying a more conservative value for the PF limit.

Therefore, NPPD concludes these proposed changes do not involve a significant reduction in a margin of safety.

Based on the responses to the above questions, NPPD concludes 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.

4.4 Conclusions 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.

5.0 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 the proposed amendment, which would change the surveillance requirement, does not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluent that might be

NLS2010006 Page 10 of 10 released offsite, or (3) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria 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.

6.0 REFERENCES

6.1 NUREG 1433, Revision 3.1, Standard Technical Specifications (STS) General Electric Plants, BWR/4.

6.2 Peach Bottom Atomic Power Station request submitted June 24, 2004 to incorporate 25 generic changes made to NUREG-1433, "Standard Technical Specification General Electric BWR [boiling-water reactor]-4 Plants" including TSTF-276-A, Revision 2, (Docket Nos. 05000277 and 05000278, ML052910355) approved under Amendment 259 to License DPR-44 and Amendment 262 to License DPR-56 dated May 10, 2006.

NLS2010006 Page 1 of 2 Attachment 2 Proposed Technical Specification Revision (Markup)

Cooper Nuclear Station, Docket No. 50-298, DPR-46 Revised Technical Specification Page 3.8-8

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.9 -----------

NOTES ---------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not be performed in MODE 1 or 2. However,-credit may be taken for unplanned events that satisfy this SR.

/

/erify each DG epeF**.A, at a Bewc, ;Botor c U.U

)perates for > 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />s:

18 months

a. For > 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded Ž 4200 kW and *4400 kW; and

b. For the remaining hours of the test loaded >

3600 kW and

• 4000 kW.

SR .8. 1.10 ----------- NOTE----------

This Surveillance shall not be performed in MODE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load is within

+ 10% of nominal timer setpoint. 18 months (continued)

TSTF-276-A Rev 2 insert with CNS corrected PF

3. If performed with DG synchronized with offsite power, the surveillance shall be performed at a power factor < 0.89.

However, ifgrid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Cooper 3.8-8 Amendment No. 178

NLS2010006 Page 1 of 2 Attachment 3 Proposed Technical Specification Revision (Re-Typed)

Cooper Nuclear Station, Docket No. 50-298, DPR-46 Revised Technical Specification Page 3.8-8

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.9 --------------------- NOTES ---------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.

3. If performed with DG synchronized with offsite power, the surveillance shall be performed at a power factor < 0.89. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG operates for > 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />s: 18 months

a. For > 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded > 4200 kW and < 4400 kW; and

b. For the remaining hours of the test loaded >

3600 kW and < 4000 kW.

SR 3.8.1.10 --------------------- NOTES ---------------

This Surveillance shall not be performed in MODE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load is within 18 months

+ 10% of nominal timer setpoint.

(continued)

Cooper 3.8-8 Amendment No.

NLS2010006 Page 1 of 4 Attachment 4 Proposed Technical Specification Bases Revisions (Information Only)

Cooper Nuclear Station, Docket No. 50-298, DPR-46 Revised Technical Specification Bases Pages Insert 2 - TSTF-276-A Rev 2 insert with CNS corrected PF B 3.8-21 B 3.8-22

Insert 2 - TSTF-276-A Rev 2 insert with CNS corrected PF Note 3 ensures that the DG is tested under load conditions that are as close to worst case design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of s 0.89. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 3 allows the surveillance to be conducted at a power factor other than < 0.89. These conditions occur when grid voltage is high, and the additional field excitation needed to obtain a power factor of < 0.89 results in voltages on the emergency busses that are too high. Under these conditions, the power factor should be maintained as close as practicable to 0.89 while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.89 may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to 0.89 without exceeding the DG excitation limits.

AC Sources-- Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.8 REQUIREMENTS (continued) Transfer of each 4.16 kV critical bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads. The 18 month Frequency of the Surveillance is based on engineering judgment taking into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed on the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems.

Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.9 Consistent with IEEE 387-1995 (Ref. 15), Section 7.5.9 and Table 3, this SR requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> -6 hours of which is at a load equivalent to 90-100% of the continuous rating of the DG, and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of which is at a load equivalent to 105% to 110% of the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions.

The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual Deleted per loading, discussed in SR 3.8.1.3, are applicable to this SR.

TSTF-276-A Rev 2 In ord.r....to that.. the DG Or, te*ted un.dcr load cndition. that.ro. as l... Vto decign conditionc ac pocciblol, tocting mRUct 138 pcrWfomd ucing a powor facator _ 0.0.

T-hic poWor factor ic chocon to 13o roproont;#Ativo of the actual design basis inductive loading that the IDG could Revision 0 B 3.8-21 Cooper Cooper B 3.8-21 Revision 0

Inet clarifies load range)

Generator loadings less than 90% occurring during the first 10 seconds of accident loading are bounded by the test conditions of 90 to 100% load and AC Sources - Operating are well within the generator capability curves. B 3.8.1 BASES SURVEILLANCE SR 3.8.1.9 (continued) ,.N REQUIREMENTS N_

REQUREMNTSof 90 -100% accident load eefierec. A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in cordance with vendor recommendations in order to maintain DG OPERABILITY.

The 18 month Frequency is conservative with respect to the recommendations of IEEE 387-1995 (Ref. 15). IEEE 387-1995 (Ref. 15), Section 7.5.9 and Table 3, require this SR to be performed during refueling outages once per 24 months. The 18 month Frequency takes into consideration plant conditions required to perform the Surveillance; and is intended to be consisten xpected fuel cycle lengths.

/-three, This Surveillance has been modified by4we-Notes. Note I states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that would challenge continued steady state operation and, as a result, plant safety systems.

Credit may be taken for unplanned events that satisfy this SR.

[Inser 2 - TSTF-276-A Rev 2 insert with CNS corrected PF:I l SR 3.8.1.10 Under LOCA conditions and loss of offsite power, loads are sequentially connected to the bus by a timed logic sequence. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.

The Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(2); takes into consideration plant conditions required to perform the Surveillance; and is intended to beconsistent with expected fuel cycle lengths.

Cooper B 3.8-22 Revision 0

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4 4

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© Correspondence Number: NLS2010006 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 None PROCEDURE 0.42 REVISION 23 PAGE 3 OF 25