ML052620413

License Amendment 212 Revision of the Required Channels Per Trip System for Primary and Secondary Containment Isolation and Control Room Emergency Filter System Instrumentation

ML052620413
Person / Time
Site:	Cooper
Issue date:	10/27/2005
From:	Michelle Honcharik NRC/NRR/DLPM/LPD4
To:	Edington R Nebraska Public Power District (NPPD)
Honcharik M, NRR/DLPM, 301-415-1774
Shared Package
ML053050418	List: ML052620413 ML060170623
References
TAC MC5031
Download: ML052620413 (13)

Text

October 27, 2005 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT RE: REVISION OF THE REQUIRED CHANNELS PER TRIP SYSTEM FOR PRIMARY AND SECONDARY CONTAINMENT ISOLATION AND CONTROL ROOM EMERGENCY FILTER SYSTEM INSTRUMENTATION (TAC NO. MC5031)

Dear Mr. Edington:

The Commission has issued the enclosed Amendment No. 212 to Facility Operating License No. DPR-46 for the Cooper Nuclear Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated October 25, 2004, as supplemented by letter dated August 1, 2005.

The amendment would revise the required channels per trip system for several instrument functions contained in TS Tables 3.3.6.1-1, Primary Containment Isolation Instrumentation, 3.3.6.2-1, Secondary Containment Isolation Instrumentation, and 3.3.7.1-1, Control Room Emergency Filter System Instrumentation.

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,

/RA/

Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 212 to DPR-46

2. Safety Evaluation cc w/encls: See next page

Mr. Randall K. Edington October 27, 2005 Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT RE: REVISION OF THE REQUIRED CHANNELS PER TRIP SYSTEM FOR PRIMARY AND SECONDARY CONTAINMENT ISOLATION AND CONTROL ROOM EMERGENCY FILTER SYSTEM INSTRUMENTATION (TAC NO. MC5031)

Dear Mr. Edington:

The Commission has issued the enclosed Amendment No. 212 to Facility Operating License No. DPR-46 for the Cooper Nuclear Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated October 25, 2004, as supplemented by letter dated August 1, 2005.

The amendment would revise the required channels per trip system for several instrument functions contained in TS Tables 3.3.6.1-1, Primary Containment Isolation Instrumentation, 3.3.6.2-1, Secondary Containment Isolation Instrumentation, and 3.3.7.1-1, Control Room Emergency Filter System Instrumentation.

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,

/RA/

Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 212 to DPR-46

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

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RidsAcrsAcnwMailCenter TS: ML060170623 NRR-100 ACCESSION NO: ML052620413 PKG.: ML053050418 NRR-058 OFFICE PDIV-2/PE PDIV-1/PM PDIV-1/LA EEIB-A/SC OGC PDIV-1/SC NAME DDuvigneaud MHoncharik DBaxley AHowe DFruchter (NLO) DTerao DATE 10/13/05 10/13/05 10/12/05 08/15/2005 10/21/05 10/21/05 OFFICIAL RECORD COPY

NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 212 License No. DPR-46

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

A. The application for amendment by Nebraska Public Power District (the licensee) dated October 25, 2004, as supplemented by letter dated August 1, 2005, 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.

2

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 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. 212, are hereby incorporated in the license. The Nebraska Public Power District 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 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

David Terao, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: October 27, 2005

ATTACHMENT TO LICENSE AMENDMENT NO. 212 FACILITY OPERATING LICENSE NO. DPR-46 DOCKET NO. 50-298 Replace the following pages of the 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.

REMOVE INSERT 3.3-51 3.3-51 3.3-52 3.3-52 3.3-53 3.3-53 3.3-57 3.3-57 3.3-63 3.3-63

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 212 TO FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298

1.0 INTRODUCTION

By letter dated October 25, 2004 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML043030300), as supplemented by letter dated August 1, 2005 (ADAMS Accession No. ML052170167), Nebraska Public Power District (the licensee) requested a license amendment for the Cooper Nuclear Station (CNS). The proposed changes revise CNS Technical Specification (TS) Tables 3.3.6.1-1, 3.3.6.2-1, and 3.3.7.1-1. These changes implement a change to the required channels per trip system for primary and secondary containment isolation and control room emergency filter system (CREFS) instrumentation. The supplement dated August 1, 2005, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register.

2.0 REGULATORY EVALUATION

The function of the primary and secondary containment isolation instrumentation is to automatically initiate isolation of the primary and secondary containment to limit the release of radioactive materials during analyzed accidents or transients to within the limits as specified in Title 10 of the Code of Federal Regulations (10 CFR) Part 100 and 10 CFR Part 20. The CREFS instrumentation automatically initiates action to pressurize the main control room to minimize the consequences of radioactive material in the control room environment to ensure the habitability of the control room for the safety of the control room operators under all plant conditions.

The primary and secondary containment isolation and CREFS instrumentation TSs specify the minimum number of required channels per trip system to ensure that no single failure will preclude an isolation when a valid signal is present in either trip system. The licensee proposes to revise the REQUIRED CHANNELS PER TRIP SYSTEM requirements in these TS tables to reflect the CNS design basis.

The NRC staff used 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 21, Protection system reliability and testability, and GDC 24, Separation of protection and control

systems, to evaluate the acceptability of the proposed changes to the number of required channels per trip system of reactor vessel water level, drywell pressure, and reactor building ventilation exhaust plenum radiation at which five automatic actions occur: (1) isolation of the primary containment, (2) isolation of reactor water cleanup (RWCU) system, (3) isolation of residual heat removal (RHR) shutdown cooling system, (4) isolation of secondary containment, and (5) initiation of the CREFS in TS Tables 3.3.6.1-1, 3.3.6.2-1, and 3.3.7.1-1.

3.0 TECHNICAL EVALUATION

3.1 The Proposed TS Changes The licensee proposed the following plant TS changes to revise the required channels per trip system from four to two.

(1) TS Table 3.3.6.1-1, Primary Containment Isolation Instrumentation, Function 2.a, Reactor Vessel Water Level - Low (Level 3), Function 2.b, Drywell Pressure - High, and Function 2.c, Reactor Building Ventilation Exhaust Plenum Radiation - High.

(2) TS Table 3.3.6.1-1, Primary Containment Isolation Instrumentation, Function 5.d, Reactor Vessel Water Level - Low Low (Level 2), and Function 6.b, Reactor Vessel Water Level - Low (Level 3).

(3) TS Table 3.3.6.2-1, Secondary Containment Isolation Instrumentation, Function 1, Reactor Vessel Water Level - Low Low (Level 2), Function 2, Drywell Pressure -

High, and Function 3, Reactor Building Ventilation Exhaust Plenum Radiation - High.

(4) TS Table 3.3.7.1-1, Control Room Emergency Filter System Instrumentation, Function 1, Reactor Vessel Water Level - Low Low (Level 2), Function 2, Drywell Pressure - High, and Function 3, Reactor Building Ventilation Exhaust Plenum Radiation - High.

The CNS TS bases have also been modified to make the appropriate changes necessary to reflect the change request. The bases change will be made under the provisions of 10 CFR 50.59 and TS 5.5.10 (TS Bases Control Program).

3.2 The CNS Protection System Design Configuration The instrumentation functions that are affected by the proposed amendment are related to high drywell pressure, low reactor water level (level 3), low low reactor water level (level 2), and high reactor building ventilation exhaust plenum radiation signals. The high drywell pressure or low reactor water level signal will form a Group 2 primary containment isolation signal. The high drywell pressure, low reactor water level, or high reactor building ventilation exhaust plenum radiation signal will form a Group 6 primary containment isolation signal. During the Improved TS (ITS) conversion process, the number of required channels per trip system was changed from two to four. This change was based on ITS convention that defined each divisional logic to be one trip system. Since all four channels provided input signals in that division/trip system logic, the result was that there be four required channels per trip system. However, the CNS design basis defines each divisional logic as having two trip systems, with two required channels per trip system.

The licensee stated that since the ITS conversion was issued, it has been found to be confusing with the inconsistency between the design and licensing basis. The updated safety analysis report (USAR) Section VII-3.3.5 states the primary containment isolation system (PCIS) logic as follows:

The logic arrangement for important trip functions is controlled by two trip systems.

Where many isolation valves close on the same signal, two trip systems control the entire group. Where just one or two valves must close in response to a special signal, two trip systems may be formed from the instruments provided to sense the special condition. Each trip system has a pair of logics. Each logic receives input signals from at least one channel for each monitored variable. Thus two channels are required for each important monitored variable to provide independent inputs to the logic of one trip system. A total of 4 channels for each important monitored variable are required for the logics of both trip systems.

The actuators associated with a logic pair provide inputs to each of the actuator logics for that trip system. Thus, either of the two logics associated with one trip system can produce a trip system trip. The logic is a 1-out-of-n arrangement, where n may be 2 or more. To initiate valve closure the actuator logics of both trip systems must be tripped.

The overall logic of the system could be termed 1-out-of-2 taken twice.

The licensee performed analysis to verify that the proposed changes do not alter the instrumentation design or the physical configuration, and will not affect the operation or manner of control to ensure that the system continues to perform its intended safety function.

The proposed amendment will lower the required channels per trip system from four to two for the following four instrumentation functions: (1) high drywell pressure, (2) low reactor water level (level 3), (3) low low reactor water level (level 2), and (4) high reactor building ventilation exhaust plenum radiation signal. The proposed changes affect primary and secondary containment isolation, RWCU system isolation, RHR shutdown cooling system isolation, and CREFS instrumentation. The required channels per trip system ensures that no single failure will preclude an isolation when a valid signal is present.

During the reviews of proposed license amendment associated with changes to the TS, the NRC staff identified the need to understand the change which was introduced during the ITS conversion process and the current logic trip system configuration. To verify the current CNS design basis, NRC staff requested the licensee to provide additional information related to the ITS conversion process and the configuration of trip system and channel logic.

By letter dated August 1, 2005, the licensee provided the ITS submittal pages and the markup of the Custom TS (CTS) pages. The ITS submittal acknowledged the ITS deviation from the CNS USAR convention of having two trip system for each divisional logic, with two channels per trip system, but CNS was unable to find any additional internal documentation as to why this convention was used in the ITS submittal.

The August 1, 2005, submittal shows that there are two trip systems that input into one divisional logic, and each trip system is composed of two low reactor water level channels and two high drywell pressure channels. Although this logic is replicated for the inboard and outboard isolation valve, there is a total of four channels for both divisions.

As described in the USAR, CNS currently has two channels that input into each trip system.

The two channels per trip system ensure that no single failure will preclude an isolation when a valid signal is present. Therefore, the CNS design has satisfied the GDC 21 and GDC 24 requirements with respect to the redundancy and independence of the protection system. No single failure of any component or channel of a system will result in loss of the protection function.

3.3 Evaluation of Proposed TS Changes (1) TS Table 3.3.6.1-1, Primary Containment Isolation Instrumentation Table 3.3.6.1-1 identifies plant parameters (functions) that cause isolation of primary containment. The table also identifies the plant modes in which the functions are applicable, the number of channels required for each trip system, applicable surveillance requirements (SRs), and the allowable value for each function that causes primary containment isolation.

The licensee proposes to change the number of channels required for each trip system to read "2" for Function 2.a, Reactor Vessel Water Level - Low (Level 3), Function 2.b, Drywell Pressure - High, Function 2.c, Reactor Building Ventilation Exhaust Plenum Radiation - High, Function 5.d, Reactor Vessel Water Level - Low Low (Level 2), and Function 6.b, Reactor Vessel Water Level - Low (Level 3).

Based on the trip system configuration as described in Section 3.2 above, CNS currently has two channels that input into each trip system. Therefore, the maximum number of channels per trip system is two. The NRC staff finds that the change of the number of channels required per trip system does not alter the instrumentation design or the physical configuration, and that the change is in conformance with 10 CFR Part 50, Appendix A, GDC 21 and GDC 24. The revised TS is consistent with NUREG-1433, General Electric Plants BWR/4 Standard TS.

Therefore, the proposed TS changes are acceptable.

(2) TS Table 3.3.6.2-1, Secondary Containment Isolation Instrumentation Table 3.3.6.2-1 identifies plant parameters that cause isolation of secondary containment.

The table also identifies the plant modes in which the functions are applicable, the number of channels required for each trip system, applicable SRs, and the allowable value for each function that causes secondary containment isolation. The licensee proposes to change the number of channels required for each trip system to read "2" for Function 1, Reactor Vessel Water Level - Low Low (Level 2), Function 2, Drywell Pressure - High, and Function 3, Reactor Building Ventilation Exhaust Plenum Radiation - High.

Based on the trip system configuration as described in Section 3.2 above, CNS currently has two channels that input into each trip system. Therefore, the maximum number of channels per trip system is two. The NRC staff finds that the change of the number of channels required per trip system does not alter the instrumentation design or the physical configuration, and that the change is in conformance with 10 CFR Part 50, Appendix A, GDC 21 and GDC 24. The revised TS is consistent with NUREG-1433, General Electric Plants BWR/4 Standard TS.

Therefore, the proposed TS changes are acceptable.

(3) TS Table 3.3.7.1-1, Control Room Emergency Filter System Instrumentation Table 3.3.7.1-1 identifies plant parameters that cause the actuation of the CREFS. The table also identifies the plant modes in which the functions are applicable, the number of channels required for each trip system, applicable SRs, and the allowable value for each function that actuates CREFS. The licensee proposes to change the number of channels required for each trip system to read "2" for Function 1, Reactor Vessel Water Level - Low Low (Level 2),

Function 2, Drywell Pressure - High, and Function 3, Reactor Building Ventilation Exhaust Plenum Radiation - High.

Based on the trip system configuration as described in Section 3.2 above, CNS currently has two channels that input into each trip system. Therefore, the maximum number of channels per trip system is two. The NRC staff finds that the change of the number of channels required per trip system does not alter the instrumentation design or the physical configuration, and that the change is in conformance with 10 CFR Part 50, Appendix A, GDC 21 and GDC 24. The revised TS is consistent with NUREG-1433, General Electric Plants BWR/4 Standard TS.

Therefore the proposed TS changes are acceptable.

3.4 Technical Evaluation Conclusion Based on the review submittals for the CNS license amendment request dated October 25, 2004, and August 1, 2005, the NRC staff finds that the proposed TS changes on the required channels per trip system for primary and secondary containment isolation, RWCU system isolation, RHR shutdown cooling system isolation, and CREFS instrumentation are in conformance with 10 CFR Part 50, Appendix A, GDC 21 and GDC 24. The revised TS is consistent with NUREG-1433, General Electric Plants BWR/4 Standard TS. Therefore, the proposed TS changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Nebraska State official was notified of the proposed issuance of the amendment. 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. 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 January 4, 2005 (70 FR 402). 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) 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: M. Patel B. Marcus Date: October 27, 2005

Cooper Nuclear Station cc: Mr. Mike Wells, Deputy Director Missouri Department of Natural Resources Mr. William J. Fehrman P.O. Box 176 President and Chief Executive Officer Jefferson City, MO 65101 Nebraska Public Power District 1414 15th Street Senior Resident Inspector Columbus, NE 68601 U.S. Nuclear Regulatory Commission P. O. Box 218 Mr. Michael T. Boyce Brownville, NE 68321 Nuclear Assett Manager Nebraska Public Power District Regional Administrator, Region IV 1414 15th Street U.S. Nuclear Regulatory Commission Columbus, NE 68601 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. John C. McClure Vice President and General Counsel Director, Missouri State Emergency Nebraska Public Power District Management Agency P. O. Box 499 P. O. Box 116 Columbus, NE 68602-0499 Jefferson City, MO 65102-0116 Mr. Paul V. Fleming Chief, Radiation and Asbestos Licensing Manager Control Section Nebraska Public Power District Kansas Department of Health P.O. Box 98 and Environment Brownville, NE 68321 Bureau of Air and Radiation 1000 SW Jackson Mr. Michael J. Linder, Director Suite 310 Nebraska Department of Environmental Topeka, KS 66612-1366 Quality P. O. Box 98922 Mr. Daniel K. McGhee Lincoln, NE 68509-8922 Bureau of Radiological Health Iowa Department of Public Health Chairman Lucas State Office Building, 5th Floor Nemaha County Board of Commissioners 321 East 12th Street Nemaha County Courthouse Des Moines, IA 50319 1824 N Street Auburn, NE 68305 Mr. Scott Clardy, Director Section for Environmental Public Health Ms. Cheryl K. Rogers, Program Manager P.O. Box 570 Nebraska Health & Human Services Jefferson City, MO 65102-0570 System Division of Public Health Assurance Jerry C. Roberts, Director of Nuclear Consumer Services Section Safety Assurance 301 Centennial Mall, South Nebraska Public Power District P. O. Box 95007 P.O. Box 98 Lincoln, NE 68509-5007 Brownville, NE 68321 July 2005