NLS2020004, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules

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Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules
ML20111A145
Person / Time
Site: Cooper Entergy icon.png
Issue date: 04/01/2020
From: Dent J
Nebraska Public Power District (NPPD)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2020004
Download: ML20111A145 (28)
v • d • e


Text

H Nebraska Public Power District Always there when you need us 50.90 NLS2020004 April I, 2020 Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

Application to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules" Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46

Dear Sir or Madam:

Pursuant to 10 CPR 50.90, Nebraska Public Power District is submitting a request for an amendment to the Technical Specifications (TS) for Cooper Nuclear Station.

The proposed amendment would modify TS requirements in Section 1.3 and Section 3 .0 regarding Limiting Condition for Operation and Surveillance Requirement usage. These changes are consistent with Nuclear Regulatory Commission-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules." provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 .provides revised (clean) TS pages. Attachment 4 provides, for information only, existing TS Bases pages marked to show the proposed changes.

Approval of the proposed amendment is requested by April 1, 2021. Once approved, the amendment shall be implemented within 60 days.

The proposed TS changes have been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). In accordance with 10 CPR 50.91, "Notice for public comment; State consultation," a copy of this application, with attachments, is being provided to the designated State of Nebraska Official.

No regulatory commitments are made in this submittal.

If you should have any questions regarding this submittal please contact Linda Dewhirst, Regulatory Affairs and Compliance Manager, at (402) 825-5416.

COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Aoof Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com NRR

NLS2020004 Page 2 of2 I declare under penalty of perjury that the foregoing is true and correct.

Executed On: -+-~+-'ij-+/_<.IJ._~_o_*___

Date John Dent, Jr.

Vice President and Chief Nuclear Officer

/dv Attachments: 1. Description and Assessment

2. Proposed Technical Specifications Changes (Mark-up)
3. Revised Technical Specifications Pages
4. Proposed Technical Specifications Bases Changes (Mark-up) cc: Regional Administrator w/ attachments USNRC - Region IV Cooper Project Manager w/ attachments USNRC - NRR Plant Licensing Branch IV Senior Resident Inspector w/ attachments USNRC-CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Li censure NPG Distribution w/o attachments CNS Records w/ attachments

NLS2020004 Page 1 of 4 Attachment 1 Description and Assessment Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 1.0 Description 2.0 Assessment 2.1 Applicability of Safety Evaluation 2.2 Variations 3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Analysis 4.0 Environmental Evaluation

NLS2020004 Page 2 of 4

1.0 DESCRIPTION

The proposed change revises Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the Technical Specifications (TS) to clarify the use and application of the TS usage rules, as described below:

  • Section 1.3 is revised to clarify "discovery."
  • Section 1.3 is revised to discuss exceptions to starting the Completion Time at condition entry.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Nebraska Public Power District (NPPD) has reviewed the safety evaluation for TSTF-529 provided to the Technical Specifications Task Force (TSTF) in a letter dated April 21, 2016 (ADAMS Accession No. ML16060A455). This review included a review of the Nuclear Regulatory Commission (NRC) staffs evaluation, as well as the information provided in TSTF-529. NPPD has concluded that the justifications presented in the TSTF-529 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 the CNS TS.

2.2 Variations NPPD is not proposing any variations from the TS changes described in the TSTF-529 or the applicable parts of the NRC staffs safety evaluation dated April 21, 2016.

One difference from the proposed TS Bases changes described in TSTF-529 should be noted for CNS. Under the TS Bases section LCO 3.0.4, TSTF-529 proposes changing the specifications typically applied to LCO 3.0.4.c from "(e.g., Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient)" to "(e.g., RCS Specific Activity)." This specific change was implemented previously at CNS, and therefore, requires no further modification to the TS Bases to be consistent with the changes described in TSTF-529.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Nebraska Public Power District (NPPD) requests adoption of Technical Specifications Task Force TSTF-529, "Clarification Use and Application Rules," that is an approved change to the standard technical specifications, into the Cooper Nuclear Station Technical Specifications (TS).

NLS2020004 Page 3 of 4 The proposed change revises Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" of the TS to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3. Section 1.3 is modified to clarify the concept of "discovery" that a Limiting Condition for Operation (LCO) is not met and to describe existing exceptions to the start of Completion Times in the TS. An editorial change is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed.

NPPD has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed changes to Section 1.3 and LCO 3 .0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of the TS actions. The proposed change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed change does not significantly affect system Operability, the proposed change will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change to the TS usage rules does not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions taken when plant systems are not operable.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

NLS2020004 Page 4 of 4 The proposed change clarifies the application of Section 1.3 and LCO 3.0.4 and does not result in changes in plant operation. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed and there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3 .0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the above, NPPD concludes that the requested change 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22( c)(9).

Therefore, pursuant to 10 CFR 5 l .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

NLS2020004 Page 1 of 5 Attachment 2 Proposed Technical Specifications Changes (Mark-up)

Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Pages 1.3-1 3.0-2 3.0-4

NLS2020004 Page 2 of 5 Insert 1 (TS Section 1.3, page 1.3-1)

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.

While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)."

In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation {LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times{s).

DESCRIPTION

[INSERT 1]

u

[start new paragraph]

If situations are discovered that require entry into more than one Condition at a time within a single LCO {multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time af discovery ~o.,_f~~~~~--.

the situation that required entry into the Condition , unless otherwise

. . specified Once a Condit1on has been entered, subsequent division.,..,-'--~~~~~__ __.

subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into *the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with

  • Completion Times based on initial entry into the Condition.

, unless otherwise specified

{continued)

Cooper 1.3-1 Amendment No. -118-

LCO Applicability 3.ci 3.0 LCO APPLICABILITY LC0.3.0.4

( continued)

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriat :. xceptions to this Specification are stated in the
  • ( ivid ecification~
c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACllONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event. additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. *

(continued)

Cooper Amendment No.~

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions.in the Applicability for individual LCOs. unless otherwise stated in the SR. Failure to meet a Surveillance.

whether such failure is experienced during the performance of the Surveil 1ance or between *performances of the Surveillance. shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.*

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once." the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per . . . "basis.the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency. then compliance with the requirement to declare the LCD not met may be delayed. from the time of discovery. up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency. whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance layed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shal be managed.

The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

(continued)

Cooper 3.0-4 Amendment No. HS. 197 MAR 86 319

NLS2020004 Page 1 of6 Attachment 3 Revised Technical Specifications Pages Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Pages 1.3-1 1.3-2 1.3-3*

3.0-2 3.0-4

  • Page included because of movement of paragraphs to subsequent pages.

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g.,

inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Tim begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

(continued)

Cooper 1.3-1 Amendment No.

Completion Times 1.3 1.3 Completion Times DESCRIPTION If situations are discovered that require entry into more than one (continued) Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and
b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the

( continued)

Cooper 1.3-2 Amendment No.

Completion Times 1.3 1.3 Completion Times DESCRIPTION Completion Time is referenced from a previous completion of the (continued) Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Condition A and B in Example 1.3-3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and associated Completion AND Time not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition Bare to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for reaching MODE 4 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

(continued)

Cooper 1.3-3 Amendment No.

L

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 a. When the associated ACTIONS to be entered permit continued (continued) operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or
c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)."

If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

(continued)

Cooper 3.0-2 Amendment No.

L

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.

Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval* specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per ... "

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

(continued)

Cooper 3.0-4 Amendment No.

NLS2020004 Page 1 of 11 Attachment 4 Proposed Technical Specifications Bases Changes (Mark-up)

Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Pages B 3.0-1 B 3.0-3 B 3.0-4 B 3.0-5 B 3.0-8 B 3.0-9 B 3.0-15 B 3.0-16

NLS2020004 Page 2 of 11 INSERT 1 (TS Bases LCO 3.0.4, page B 3.0-5)

For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time.

Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION

("Required Action and associated Completion Time not met") allows the OPERABLE train to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

INSERT 2 (TS Bases LCO 3.0.5, page B 3.0-8)

LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

INSERT 3 (TS Bases LCO 3.0.5, page B 3.0-9)

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, ifthere is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples INSERT 4 (TS Bases LCO 3.0.5, page B 3.0-9)

The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

NLS2020004 Attachment 4 Page 3 of 11 INSERT 5 (TS Bases SR 3.0.3. page B 3.0-16)

SR 3.0.3 is only applicable ifthere is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

L_

INFORMATION ONLY LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specificatlon).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that m be taken within specified Completion Times when the requirements o an LCO are not met. This Specification establishes that: , unless otherwise specified

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable.

(Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering Cooper B 3.0-1 06/30.'06 INFORMATION ONLY

INFORMATION ONLY LCO Applicability B 3.0 BASES (continued)

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a. An associated Required Action and CompletionTime is not met and no other Condition applies; or
b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits s ecified t lower MODES of enter m1 e s utdown to procee in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

Cooper B 3.0-3 10/1§.'19 INFORMATION ONLY

INFORMATION ONLY LCO Applicability B 3.0 BASES LCO 3.0.3 A unit shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:

a. The LCO is now met .
b. The LCO is no .:..e.~ndition exists for which the Required Actions have longer applicable. now been performed.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 4 when a shutdown is required during

  • MODE 1 operation. If the unit is in a lower MODE of

.----~-.--, . operation when a shutdown is required, the time limit for

!entering I >l"eaehiA!:J the next lower MODE applies. If a lower MOOE is entered reached in less time than allowed, however, the total

~ allowable time t ~ MODE 4, or other applic ODE, is not re . o example, if MODE 2 is in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, enter n the time allowe MODE 3 is the next

.I , ause the total time MOOE 3 is not entering <reduced from t 1mit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if entering measures are completed that would permit a return to MODE I, a penalty is not incurred b

  • i"-eitfl- a lower MO
  • an the total time allowed.

enter In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE I, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.6, ttSpent Fuel Storage Pool Water Level." LCO 3.7.6 has an Applicability of "During movement of irradiated fuel (continued)

Cooper B 3.0-4 RevisiaA e INFORMATION ONLY

INFORMATION ONLY LCO Applicability B 3.0 BASES LCO 3.0.3 (continued) assemblies in the spent fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.6 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.6 to "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met,

.-----.I in accordance wi~ LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

!either :

LCO 3.0.4.a allows entry into a MODE or other specified condition in the following entry into licability with the LCO not met when the associated ACTIONS to be will permit continued entere * * *

  • the MODE or other specified operation within the condition in the Ao
  • for an unlimited period of time. Compliance MODE or other specified that permit continued operation of the unit for an condition unlimit period of time in a MODE or other specified condition provides

......-------. an ceptable level of safety for continued operation. This is without ACTIONS gard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition and the Required Actions L~i;n~th=e~A~p~p:lic~a:b:iri1ty~m~ay~be~m!§lalQ.d§jfH*!06l=aa-AeE~tA-'!Ae--f*Wffi;teA:&-eHA1&

followed after entry into the Applicability. ~-.[INSERT 1]

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results. determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

Cooper B 3.0-5 09/1S/09 INFORMATION ONLY

INFORMATION ONLY LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits} and restoring compliance with the affected LCO.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or
b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs. This Specification does not provide time to perform any other preventive or corrective maintenance. (  ![INSERT 2] I Afl example of demonstFatiA§ the OPERABILITY of tt=ie O<'!uipment being rntuFnoa to sorviso is reopening a sontainrnont isolation val*o<e tl:lat

  • has boon sl9sea to sgr:nply with Roqbliroa Astions ana ffil:lst so rooponoEf to porforffi tho SRs.

Cooper B 3.0-8 09/18/09 INFORMATION ONLY

INFORMATION ONLY LCO Applicability B 3.0 BASES LCO 3.0.5 (continued) ~

are

~ A n mmA'lple of demonstrating the OPERABILITY of other equipment

  • taking an inoperable channel or trip system out of the tripped conditionf _

prevent the trip function from occurring during the performance of an SK '--ill]

on another channel in the other trip syste~ siEBilar e>ffifflple e,f demonstrating tho 0PERAB1b1TY of othor equipR'lont is taking an I, or 2 ) I inoJ;)eFBble channel or triJ;) systeR'I o~t of the tripJ;)ed eonElition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.

~

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support systems' LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Cooper B 3.0-9 09118189 INFORMATION ONLY

INFORMATION ONLY SR Applicability B 3.0 BASES SR 3.0.2 (continued)

When a Section 5.5, "Programs and Manuals," Specification states that the provisions of SR 3.0.2 are applicable, a 25% extension of the testing interval, whether stated in the Specification or incorporated by reference, is permitted.

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. Examples of where SR 3.0.2 does not apply are the Containment Leakage Rate Testing Program required by 10 CFR 50, Appendix J, and the inservice testing of pumps and valves in accordance with applicable American Society of Mechanical Engineers Operation and Maintenance Code, as required by 10 CFR 50.55a. These programs establish testing requirements and Frequencies in accordance with the requirements of the regulations. The TS cannot in and of themselves extend a test interval specified in the regulations, directly or by reference.

As stated in SR 3.0.2, the 25o/o extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per... " basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly R'leFOly as aR gpei:ati8Ral 68R'~Ri&RG9 to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not be within the specified Frequency. A performed e ay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance Cooper B 3.0-15 08109/17 INFORMATION ONLY

INFORMATION ONLY SR Applicability B 3.0 BASES SR 3.0.3 (continued) with SR 3.0.2, and not at the time that the specified Frequency was not met.

When a Section 5.5, "Programs and Manuals," Specification states that the provisions of SR 3.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 3.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 3.0.2 if invoked by the Section 5.5 Specification). """

pe,1orm performance This delay period provides adequate time to llances that have been missed. This delay period permits the of a Surveillance before complying with Required Actions or other remedial measures that might preclude

  • of the Surveillance.

performance The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not to have been performed when specified, SR 3.0.3 allows the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

![INSERT 5] i - !- . . : : : . . ~

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is-..---~

a flexibility which is not intended to be used as an opeFational ( !repeatedly I conv~niem:e to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant Cooper B 3.0-16 08/99/17 INFORMATION ONLY

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