NLS2005093, Response to NRC Request for Additional Information License Amendment Request to Adopt Generic Changes to Standard Technical Specifications, Cooper Nuclear Station
| ML052790490 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/29/2005 |
| From: | Edington R Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2005093 | |
| Download: ML052790490 (7) | |
Text
N Nebraska Public Power District Always there when you need us NLS2005093 September 29, 2005 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Subject:
Response to NRC Request for Additional Information Re: License Amendment Request to Adopt Generic Changes to Standard Technical Specifications Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
- 1.
Letter from Michelle C. Honcharik, U.S. Nuclear Regulatory Commission, to Randall K. Edington, Nebraska Public Power District, dated September 2, 2005, "Request for Additional Information Re: License Amendment Request to Adopt Generic Changes to Standard Technical Specifications (TAC NO. MC6760)"
- 2.
Letter from Randall K. Edington, Nebraska Public Power District, to U.S. Nuclear Regulatory Commission, dated April 13, 2005, "License Amendment Request to Adopt Generic Changes to Standard Technical Specifications" The purpose of this letter is to submit the Nebraska Public Power District's response to the Nuclear Regulatory Commission's Request for Additional Information (Reference 1). The response is attached.
The information in this submittal does not change the No Significant Hazards Consideration included in the original license amendment request (Reference 2).
Should you have any questions concerning this matter, please contact Paul Fleming, Licensing Manager, at (402) 825-2774.
I declare under penalty of perjury that the foregoing is true and correct.
COOPER NUCLEAR STATION P.O. Box 98 / Brownville. NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2005093 Page 2 of 2 Executed on 3 l5 Randhll K. Edington i
Vice President - Nuclear and Chief Nuclear Officer Irr Attachment cc: Regional Administrator %v/attachment USNRC - Region IV Senior Project Manager W/attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector xv/attachment USNRC - CNS NPG Distribution w/attachment
NLS2005093 Attachment Page 1 of 4 Attachment Response to NRC Request for Additional Information Regarding License Amendment Request to Adopt Generic Changes to Standard Technical Specifications Nebraska Public Power District Cooper Nuclear Station
Reference:
Letter from Randall K. Edington, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission dated April 13, 2005, "License Amendment Request to Adopt Generic Changes to Standard Technical Specifications" NRC Ouestion No. 1 The proposed note 2 to surveillance requirement (SR) 3.8.2.1 states that "SR 3.8.1. 11 is considered to be met wvithout the ECCS initiation signals OPERABLE wthen the ECCS initiation signals are not required to be OPERABLEper Table 3.3.5.1-1. " This is not consistent with TSTF 300-A, Rev. 0 which states "SR 3.8.1.12 and SR 3.8.1.19 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "ECCS - Shutdoi'n. "
a)
The proposed note states that SR 3.8.1. 11 is considered to be met. Provide a justification for this modification. In addition, explain what does "considered to be met " mean? Also, provide the status of SR 3.8. 1. 11 during "ECCS - Shutdown."
NPPD Response The first part of the question requests justification for the difference between the note proposed for CNS and the note in TSTF-300. The note proposed for SR 3.8.2.1 in the reference letter stated that SR 3.8.1.11 "is considered to be met," rather than "are not required to be met" as stated by the note in TSTF-300 because certain portions of SR 3.8.1.11 are required to be met when in Mode 4 (Cold Shutdown) or Mode 5 (Refueling). As explained on page 9 of Attachment I in the reference, CNS SR 3.8.1.11 bounds (encompasses) SR 3.8.1.11, SR 3.8.1.12, and SR 3.8.1.19 from NUREG-1433, Standard Technical Specifications (TS) for BWR/4 Plants. Because CNS has one SR rather than the three in Standard TS, portions of SR 3.8.1.11 are required to be met when no Emergency Core Cooling System (ECCS) subsystems are required to be operable with the plant in Mode 5. (Based on the Applicability of Technical Specification 3.5.2, "ECCS - Shutdown," ECCS is not required in MODE 5 with the spent fuel pool gates removed and water level 21 foot or greater above the top of the reactor pressure vessel flange). Because portions of SR 3.8.1.11 are required to be met when in Mode 5, it would be incorrect to state that SR 3.8.1.11 "is not required to be met" as is proposed in TSTF-300.
NLS2005093 Attachment Page 2 of 4 CNS addressed the difference between the note in TSTF-300 and the note proposed for CNS in item 3 of Section 4.0, Technical Analysis, in Attachment 1 of the reference. That discussion mentioned Duane Arnold Energy Center (DAEC) Amendment No. 234 dated October 3, 2000. NPPD intentionally worded the note proposed for CNS exactly as the note issued to DAEC, with the exception of the referenced SR numbers which are site-specific.
The NRC addressed this difference in the safety evaluation (SE) issued with the DAEC amendment. On page 9 of that SE, it is stated:
"In its application, the licensee stated that the proposed change is consistent with the TSTF. However, since the NUREG SRs 3.8.1.11, 3.8.1.12, and 3.8.1.19 were combined into DAEC SR 3.8.1.13 in the conversion to the ITS, the wording of the exception is modified in order to accomplish the same result in the DAEC TS (i.e.,
eliminate the requirement for NUREG SRs 3.8.1.12 and 3.8.1.19 to be met). The NRC staff reviewed the wording in the NRC staff-approved TSTF and the DAEC proposed change, and finds that the change is the same as the TSTF, and concurs that during shutdown Modes, when the vessel is defueled or when the reactor cavity is flooded, the ECCS systems are not required to be OPERABLE and the DG ECCS start function serves no safety function. Based on this, the NRC staff concludes that the proposed change to LCO 3.8.2 (and its associated Bases) of the TS to incorporate TSTF-300 are acceptable."
The second part of the question requests explanation of the meaning of "considered to be met." SR 3.0.1 states that failure to meet a surveillance shall be failure to meet the LCO, whether such failure is experienced during performance of the surveillance or between performances. Based on SR 3.0.1 surveillances are considered to be satisfied between performances unless information that causes this to be questioned becomes known. SR 3.8.1.11 specifies certain actions that must be verified on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal. The phrase "considered to be met" means that verification of these actions is considered to be current, even with the ECCS initiation signals not functional at times when the ECCS is not required to be operable in accordance with TS Section 3.5.2, "ECCS - Shutdown."
The last part of this question was to provide the status of SR 3.8.1.11 when the plant is shut down (i.e., during "ECCS-Shutdown"). CNS is currently operating on an 18-month operating cycle. The frequency of SR 3.8.1.11 is 18 months. Following a normal cycle of 18 months, SR 3.8.1.11 would be within the 18-month frequency when entering Mode 4, at which time LCO 3.8.2, "ECCS - Shutdown" would become applicable. However, in the event of a longer operating cycle, such that the frequency requirements of SR 3.0.2 would not be met for SR 3.8.1.11, the current note in SR 3.8.2.1 would allow the associated DG(s) to remain operable without performing SR 3.8.1.11.
NLS2005093 Attachment Page 3 of 4 b.)
Explain why the proposed note did not include the statement that associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "ECCS - Shutdowvn."
NPPD Response The note added to SR 3.8.2.1 by TSTF-300 states:
"SR 3.8.1.12 and SR 3.8.1.19 are not required to be met when its associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "ECCS
- Shutdown."
Although the wording of the note proposed by CNS for TS SR 3.8.2.1 differs from that proposed in TSTF-300, the basis for each is the same and both achieve the same result. Both reflect that the ECCS signals that start the DG(s) are not required to be operable when the ECCS subsystems are not required to be operable. Both are based on the fact that when the ECCS subsystems are not required to be operable, in accordance with TS LCO 3.5.2, the ECCS signals that start the DG(s) serve no safety significant support function and therefore, are not required to be operable.
The ECCS initiation signals are identified in TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation." When the ECCS subsystems are not required to be OPERABLE by LCO 3.5.2, the ECCS initiation signals of Table 3.3.5.1-1 are not required to be OPERABLE.
It is more appropriate to reference Table 3.3.5.1-1 than LCO 3.5.2 in the note when discussing ECCS initiation signals because this table identifies the ECCS initiation signals.
NRC Question No. 2 In Section 4.3 of the amendment request, you stated that although the DG is not required to start in response to ECCS initiation signals, the DG is still required to meet the other attributes of SR 3.8.1.11 when associated ECCS initiation signals are not required to be operable per TS Table 3.3.5.1-1. Provide which attributes vill be met and holv this SR wSill be performed.
NPPD Response The "other attributes" of SR 3.8.1.11 are the functions specified in parts a, b, and c of the SR that will occur in response to a loss of offsite power. Although auto-start of the DG from standby conditions in response to an ECCS initiation signal is not required, the other actions of de-energization of the emergency buses, load shed from the buses, and DG energizing required loads and achieving proper steady state voltage and frequency, must still occur in response to a loss of offsite power. As discussed on page 9 of Attachment 1 in the reference, CNS SR 3.8.1.11 bounds SRs 3.8.1.11, 3.8.1.12, and 3.8.1.19 fromNUREG-1433, Standard Technical Specifications for BWR/4 Plants.
NLS2005093 Attachment Page 4 of 4 The current NOTE in SR 3.8.2.1 identifies SR 3.8.1.11 as one of several SRs that are not required to be performed. Although SR 3.8.1.11 is not required to be performed, SR 3.0.1 requires that plant systems and components in TS be able to meet requirements identified in applicable SRs when the plant is in the MODES or other specified conditions in the Applicability for individual LCOs. Thus, the requirements of SR 3.8.1.1 1 must be met at all times, not only when it is being performed.
SR 3.8.1.11 is not performed prior to entering MODE 4 or MODE 5 as part of a refueling outage. Rather, testing to satisfy SR 3.8.1.1 1 is performed during a refueling outage prior to startup for the next operating cycle.
I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©D i
Correspondence Number: NLS2005093 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None 4
4 4
4 PROCEDURE 0.42 l
REVISION 18 l
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