ML15216A259

Issuance of Amendment No. 252, Revise Technical Specification 3.5.2, ECCS - Shutdown, to Delete Condensate Storage Tank as Alternate Source of Makeup Water

ML15216A259
Person / Time
Site:	Cooper
Issue date:	08/27/2015
From:	Siva Lingam Plant Licensing Branch IV
To:	Limpias O Nebraska Public Power District (NPPD)
Lingam S
References
TAC MF4716
Download: ML15216A259 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 27, 2015 Mr. Oscar A. Limpias Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT REQUEST TO DELETE CONDENSATE STORAGE TANK AS AN ALTERNATE SOURCE OF MAKEUP WATER {TAC NO. MF4716)

Dear Mr. Limpias:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 252 to Renewed Facility Operating License No. DPR-46 for the Cooper Nuclear Station (CNS). The amendment deletes condensate storage tank (CST) as an alternate source of makeup water in response to your application dated August 26, 2014, as supplemented by letters dated February 25 and July 13, 2015.

The amendment would revise the CNS Technical Specifications {TSs) by deleting Option b from TS Surveillance Requirement 3.5.2.1. Option b allows use of CST A as an alternative source of makeup water to the reactor pressure vessel during MODE 4 and MODE 5, but CST A is not qualified to Seismic Category I.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Siva P. Lingam, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 252 to DPR-46

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 252 License No. DPR-46

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nebraska Public Power District (the licensee),

dated August 26, 2014, as supplemented by letters dated February 25 and July 13, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-46 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 252, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULA TORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-46 and Technical Specifications Date of Issuance: August 2 7, 2o1 5

ATTACHMENT TO LICENSE AMENDMENT NO. 252 RENEWED FACILITY OPERATING LICENSE NO. DPR-46 DOCKET NO. 50-298 Replace the following pages of the Renewed Facility Operating License No. DPR-46 and Appendix A Technical Specifications with the enclosed revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3.5-9 3.5-9

(5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2419 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 252, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Cooper Nuclear Station Safeguards Plan," submitted by letter dated May 17, 2006.

NPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NPPD CSP was approved by License Amendment No. 238 as supplemented by changes approved by License Amendments 244 and 249.

(4) Fire Protection NPPD shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated April 24, 2012 (and supplements dated July 12, 2012, January 14, 2013, February 12, 2013, March 13, 2013, June 13, 2013, December 12, 2013, January 17, 2014, February 18, 2014, and April 11, 2014), and as approved in the safety evaluation dated April 29, 2014.

Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if Amendment No. 252

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required ECCS injection/spray 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> subsystem, the suppression pool water level is ~ 12 ft 7 inches.

SR 3.5.2.2 Verify, for each required ECCS injection/spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

SR 3.5.2.3 ----------------------NOTE------------------------------

One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

Verify each required ECCS injection/spray subsystem 31 days manuaf, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

(continued)

Cooper 3.5-9 Amendment No. 252

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 252 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298

1.0 INTRODUCTION

By application dated August 26, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14246A203), as supplemented by letters dated February 25 and July 13, 2015 (ADAMS Accession Nos. ML15062A037 and ML15202A127, respectively), Nebraska Public Power District (the licensee), requested changes to the Technical Specifications (TSs) for Cooper Nuclear Station (CNS). The license amendment request (LAR) would delete condensate storage tank (CST) as an alternate source of makeup water. The proposed changes would revise the CNS TSs by deleting Option b from TS Surveillance Requirement (SR) 3.5.2.1. Option b allows use of CST A as an alternative source of makeup water to the reactor pressure vessel during MODE 4 and MODE 5, but CST A is not qualified to Seismic Category I, which could cause the safety systems to which it is connected to become technically "Inoperable." CNS revised procedures for core spray (CS) and residual heat removal (RHR) low-pressure coolant injection (LPCI) systems will note that aligning the CS or RHR pumps to take suction from CST A in MODES 4 and 5 could result in the pumps to be technically inoperable for TS purposes due to the CST being Seismic Class II and the pumps being Seismic Class I.

The supplemental letters dated February 25 and July 13, 2015, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on December 23, 2014 (79 FR 77047).

1.1 System Description The emergency core cooling system (ECCS) is designed to limit the release of radioactive materials to the environment following a loss-of-coolant accident using flooding and spraying to cool the core. The ECCS systems at CNS consist of the high-pressure coolant injection (HPCI) system, the CS system, the LPCI mode of RHR system, and the automatic depressurization system. The low-pressure ECCS injection/spray subsystems consist of two CS subsystems and Enclosure 2

two LPCI subsystems. Each CS subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or CST to the reactor pressure vessel. Each LPCI subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or CST to the reactor pressure vessel. The suppression pool provides the required source of water for the ECCS. The emergency CSTs are capable of providing a source of water for the HPCI system. CST A is capable of providing a source of water for the CS system and LPCI subsystems.

SR 3.5.2.1 requires a minimum water level of 12 feet 7 inches for the suppression pool to ensure that CS and LPCI system pumps have adequate net positive suction head. Currently, with the suppression pool water level less than the required limit, all ECCS injection and spray subsystems could be considered inoperable unless aligned to CST A.

The condensate storage system provides station system makeup, receives system reject flow, and provides condensate for any continuous service needs and intermittent batch type services.

The total stored design quantity is based on the demand requirements during refueling for filling the dryer separator pool, the reactor well, and for coping with a station blackout event.

One 450,000-gallon (CST A) and one 700,000-gallon (CST B) capacity CST supply the various station requirements. They can receive demineralized makeup water from the water treatment plant of reprocessed water from the radwaste system. The tanks are constructed of coated carbon steel with electric heaters for anti-freeze protection.

1.2 Background As reported in the LAA, TS changes related to using CST A as a suction path for CS and LPCI when draining the suppression chamber date back to Amendment No. 11 issued December 30, 1975 (ADAMS Accession No. ML021340436), and Amendment 12 issued October 6, 1975 (ADAMS Accession No. ML021340469). The licensee submitted these amendment requests to satisfy a request from the NRC to revise TSs to allow for the draining of the suppression pool and inspection of safety relief valve supports. Modifications were made to the amendments to add the use of the CST as a suction path for ECCS pumps.

In its submittal dated August 26, 2014, the licensee states that NRC inspectors questioned if the NRC had been properly apprised that CST A is a Seismic Class II, non-safety-related system, which ties into the Seismic Class I safety-related systems of the CS and LPCI systems. The inspectors questioned whether provisions in TSs, which allow alignment of ECCS to the CST, would render the ECCS pumps inoperable for TS purposes because the CST could not be relied on to survive a safe shutdown earthquake.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance which the NRC staff considered in its review of this LAA are:

• The regulations in Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.36, Technical specifications," contain the requirements for the

content of TSs. Pursuant to 10 CFR 50.36(c), TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls.

• Paragraph 10 CFR 50.36(c)(3) identifies SRs as one of the categories to be included in TSs and states that SRs are "requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."

• NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," dated December 29, 1998 (ADAMS Accession No. ML031110108), discusses the NRC's staff expectations regarding the correction of facility TSs when they are found to contain non-conservative values or specify incorrect actions. This letter also recommends that short-term corrective actions, in the form of administrative controls at the affected facility, will be followed with a formal amendment to the TS to address the non-conservative values or incorrect actions.

• Appendix A to 10 CFR Part 50, "General Design Criteria of Nuclear Power Plants," Criterion 19--Control room, provides requirements for the Control Room from which actions can be taken to operate the plant safely under normal and accident conditions.

• Section 50.120, "Training and qualification of nuclear power plant personnel," of 10 CFR Part 50, provides requirements to establish, implement, and maintain a training program.

• NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," contains acceptance criteria based on meeting the relevant requirements of the Commission regulations, specifically:

Chapter 13.2.1, Revision 3, "Reactor Operator Requalification Program; Reactor Operator Training" (ADAMS Accession No. ML070100636);

Chapter 13.5.2.1, Revision 2, "Operating and Emergency Operating Procedures" (ADAMS Accession No. ML070100635); and Chapter 18, Revision 2, "Human Factors Engineering" (ADAMS Accession No. ML070670253).

• NUREG-1764, Revision 1, "Guidance for the Review of Changes to Human Actions," September 2007 (ADAMS Accession No. ML072640413).

• NUREG-0700, Revision 2, "Human-System Interface Design Review Guidelines,"

May 2002 (ADAMS Accession Nos. ML021700373).

• NUREG-0711, Revision 3, "Human Factors Engineering Program Review Model," November 2012 (ADAMS Accession No. ML12324A013).

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes In the LAA dated August 26, 2014, the licensee proposed the following change in TS 3.5.2, "ECCS - Shutdown":

Current SR 3.5.2.1 states:

Verify, for each required ECCS injection/spray subsystem, the:

a. Suppression pool water level is ~ 12 ft 7 inches; or

b. --------------------------------------------------N()TE---------------------------------------

()nly one required ECCS injection/spray subsystem may take credit for this option during OPDRVs.1 11 Condensate storage tank (CST A) water level is ~ 14 ft.

Revised SR 3.5.2.1 would state:

Verify, for each required ECCS injection/spray subsystem, the suppression pool water level is ~ 12 ft 7 inches.

3.2 NRC Staff Evaluation In its LAA, the licensee has proposed to delete Option b from TS SR 3.5.2.1. TS SR Option b allows the use of CST A as an alternate source of makeup water to the reactor pressure vessel during MODE 4 and MODE 5. Deleting Option b would eliminate the requirement to verify ECCS CST A subsystem requirements and the associated Note. This would reconcile the potential for ECCS pumps becoming inoperable due to a seismic event that can cause the CST to fail.

Using a long-term cooling analysis, the licensee has determined that following a design basis loss-of-coolant accident only one low-pressure ECCS injection/spray system is required to provide sufficient heat removal and maintain adequate reactor vessel water level. In MODES 4 and 5, there is low pressure and low-temperature conditions, which require only one low-pressure ECCS injection/spray system to maintain adequate reactor vessel water level in the 1 Operations with a potential for draining the reactor vessel.

event of an inadvertent vessel drain down. CNS requires a minimum of two low-pressure ECCS injection or spray subsystems to be OPERABLE in MODES 4 and 5 for redundancy. When suppression pool level is less than 12 feet, 7 inches, the CS system and LPCI subsystems are considered OPERABLE only if they can take suction from CST A.

The NRC staff reviewed the proposed deletion of the option to use CST A as an alternate method to provide makeup water to the reactor pressure vessel, along with information contained in the Updated Final Safety Analysis Report (UFSAR), the current TSs.

ECCS performance is evaluated for the entire spectrum of possible break sizes including loss-of-coolant accident (LOCA) and drain-down events. NRC request for additional information (RAI) dated January 29, 2015 (ADAMS Accession No. ML15029A050) asked the licensee to describe how makeup water will be provided to the reactor pressure vessel in a drain-down event, if the ECCS is inoperable, as a result of suppression pool water level less than the required TS limit, if CST A is deleted as an alternate source of water. In its February 25, 2015 RAI response, the licensee stated that, with the suppression pool water level below 12 feet 7 inches, ECCS remains available for makeup water to the reactor pressure vessel. The licensee further described that, in the event of inadvertent drain down below 12 feet 7 inches, LCO 3.5.2 Condition C will be entered and all operations with a potential for draining the reactor vessel must be suspended immediately along with restoration of ECCS operability within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ECCS is restored using Emergency Operating Procedure 5.8.14, "Suppression Pool Make up Systems."

The licensee included methods of supplying water to the suppression pool, to restore level, using the main condensate system or reactor building auxiliary condensate booster pump. This is accomplished by aligning to the HPCI minimum flow line, the reactor core isolation cooling minimum flow line, the AHR suppression pool cooling line or the CS test line. Water sources used for level restoration are the CST A and CST B, demineralized water tank, main condenser A and B.

The NRC staff reviewed the systems used to supply water to the suppression pool to determine their safety classification. Section Xll-2.1.2.3, "Class I Equipment," of the CNS UFSAR lists the Class I systems required for safe shutdown and isolation of the reactor. All piping and components in the HPCI, reactor core isolation cooling, AHR, and CS systems are included as Class I equipment. This ensures that while in MODES 4 and 5, one low-pressure ECCS injection/spray subsystem will not be impacted by a seismic event and can maintain adequate reactor vessel water level in the event of an inadvertent vessel drain down. With Option b removed from TS SR 3.5.2.1, the suppression pool can be restored above the TS level of 12 feet 7 inches using the systems listed above, which will satisfy LCO 3.5.2 Condition C and restore ECCS to OPERABLE status.

Based on the information provided by the licensee in the LAA and RAI responses, the NRC staff concludes that the change does not affect the ability of the ECCS to maintain adequate reactor vessel water level. Therefore, the NRC staff concludes that the proposed change to TS SR 3.5.2.1 is acceptable.

3.3 Description of Operator Action(s) and Assessed Safety Significance The LAR proposed by the licensee will prohibit alignment of RHR and CS suctions to CST A during MODE 4 and MODE 5.

In accordance with the generic risk categories established in Appendix A to NUREG-1764, these task sequences are considered "of low risk-importance" due to the fact that they are prohibited for reactor cooldown during shutdown. Because of the low potential risk, the NRC staff performed a "Level Three" review (i.e., the least stringent of the graded reviews possible under the guidance of NUREG-1764).

3.4 Human-System Interface Design The NRC staff concludes that Human-System Interface design, including the design of the Safety Parameter Display System, will not be affected by the proposed LAR because no changes are being made to the design of the Control Room.

3.5 Procedure Design Removal of Option b from TSs will affect two procedures, Procedure 2.2.9, "CS System,

Revision 75, and 2.2.69.1, "RHR LPCI Mode, Revision 26. The licensee stated that this option was used infrequently and only while the plant was shut down. The licensee plans to clarify these two procedures concerning RHR and CS alignment to the CST. The NRC staff concludes that this approach to controlling operator actions is consistent with NUREG-0711 and is, therefore, acceptable.

3.6 Training Program and Simulator Design The licensee stated that, as part of the license amendment implementation, the training lesson plans for CS and RHR systems and the lesson plan for TS 3.5, "Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System," will be revised to remove reference to operability when the system is aligned to take suction from the CST. Changes to the simulator are not necessary. The NRC staff concludes that this approach to training is consistent with NUREG-0711 and 10 CFR 50.120, and is acceptable to support this proposed LAR.

3.7 Human Factors Verification and Validation Because no operator actions were added or changed, verification and validation are not necessary. This is consistent with the guidance of NUREG-0711 and, therefore, the NRC staff finds this acceptable.

3.8 Summary The NRC staff has reviewed the proposed LAR and concludes that the proposed changes are consistent with the requirements of 10 CFR 50.36 and NRC guidance for the content of the

ECCS TS. Therefore, the NRC staff concludes that the proposed amendment to delete the CST as an alternate source of makeup water, from SR 3.5.2.1 Option b, is acceptable.

The NRC staff concludes that the proposed LAR is acceptable from the stand point of procedural controls and human performance.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Nebraska State official was notified of the proposed issuance of the amendment on August 4, 2015. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, and changes SR.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on December 23, 2014 (79 FR 77047). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22{c){9}. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.

Principal Contributors: T. Sweat, NRR G. Lapinsky, NRR Date: August 27, 2015

ML15216A259 *via memo OFFICE NRR/DORL/LPL4-1 /PM NRR/DORL/LPL4-1/LA NRR/DSS/SBPB/BC NRR/DRA/APHB/BC NAME SLingam JBurkhardt GCasto* SWeerakkody*

DATE 8/5/15 8/4/15 8/3/15 7/23/15 OFFICE NRR/DSS/STSB/BC OGC (NLO) NRR/DORL/LPL4-1 /BC N RR/DORL/LPL4-1 /PM NAME RElliott (MChernoff for) MYoung MMarkley Sling am DATE 8/11/15 8/19/15