ML080520203
| ML080520203 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/22/2008 |
| From: | Lyon C NRC/NRR/ADRO/DORL/LPLIV |
| To: | Minahan S Nebraska Public Power District (NPPD) |
| Lyon C Fred, NRR/DORL/LPL4, 301-415-2296 | |
| References | |
| TAC MD7385 | |
| Download: ML080520203 (7) | |
Text
February 22, 2008 Mr. Stewart B. Minahan Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION RE: MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE (TAC NO. MD7385)
Dear Mr. Minahan:
By application dated November 19, 2007, Nebraska Public Power District (NPPD, the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) staff approval of an amendment to the Cooper Nuclear Station facility operating license and technical specifications to increase the rated thermal power from 2381 to 2419 megawatts thermal (1.62 percent increase) based upon increased feedwater flow measurement accuracy to be achieved by using high accuracy ultrasonic flow measurement instrumentation. Your proposal is a measurement uncertainty recapture power uprate.
The NRC staff has reviewed the information provided in your submittal and determined that additional information is required in order to complete its review. Please provide a response to the enclosed questions by March 21, 2008.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-2296.
Sincerely,
/RA/
Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Request for Additional Information cc w/encl: See next page
(*)memo dated OFFICE NRR/LPL4/PM NRR/LPL4/LA EICB/BC NRR/LPL4/BC NAME FLyon JBurkhardt WKemper (*)
THiltz, JND for DATE 2/22/08 2/21/08 2/20/08 2/22/08
Cooper Nuclear Station (09/2007) cc:
Mr. Ronald D. Asche President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. Gene Mace Nuclear Asset Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. John C. McClure Vice President and General Counsel Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 Mr. David Van Der Kamp Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Mr. H. Floyd Gilzow Deputy Director for Policy Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 218 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson Suite 310 Topeka, KS 66612-1366 Ms. Melanie Rasmussen Radiation Control Program Director Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319 Mr. Keith G. Henke, Planner Division of Community and Public Health Office of Emergency Coordination 930 Wildwood P.O. Box 570 Jefferson City, MO 65102 Mr. Paul V. Fleming, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. John F. McCann, Director Licensing, Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601-1813
OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE REQUEST NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 The following questions are provided from the Instrumentation and Controls Branch (EICB):
- 1.
On page 10 of Attachment 1, the submittal proposes a 72-hour Allowed Outage time (AOT) and states that the alternate instrumentation accuracy will gradually degrade over time associated with nozzle fouling and transmitter drift, but that this degradation is likely to be imperceptible for a 72-hour period. This is a qualitative statement. Based on the transmitter drift record at the plant, please provide the calculated effect of the transmitter drift on the power calorimetric during this AOT.
- 2.
How will reactor power will be calculated when the plant computer is not operable? How do/will plant procedures account for when the computer is inoperable?
- 3.
RIS 2002-03, Attachment 1,Section I.1.F requests information to address the calibration and maintenance procedures related to all instruments that affect the power calorimetric. The Nebraska Public Power District only addressed the LEFM [Leading Edge Flow Meter] on this item in Table 4-1 of Attachment 4.
Please provide the requested information for the remaining instruments.
- 4.
Provide confirmation that the UFM [ultrasonic flow measurement] mass flow uncertainty used in the total thermal power uncertainty determination includes uncertainty for the actual location of the transducers within the housing as identified in Cameron Customer Information Bulletin CIB 125, Rev.0, dated April 23, 2007.
- 5.
The license amendment request (LAR) proposes the following TS changes:
- a.
Reference to 10% RTP [rated thermal power] has been scaled down to 9.85% RTP in the following Technical Specifications [TS]:
- i.
3.1.3 CONDITION D (page 3.1.9),
ii.
3.16 APPLICABILITY (page 3.1-18),
iii.
SR 3.3.2.1.2 and 3.3.2.1.3 (page 3.3-17),
iv.
SR 3.3.2.1.6 (page 3.3-18), and
- v.
Footnote (f) of Table 3.3.2.1-1 (page 3.3-19).
- b.
Reference to 30% RTP has been scaled down to 29.5% RTP in the following TS:
- i.
3.1.1.1 Reactor Protection (RPS) Instrumentation REQUIRED ACTION E.1 (page 3.3-2), and related TS SR 3.3.1.1.14 (page 3.3-5);
ii.
Table 3.3.1.1-1, FUNCTION 8 and 9, APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS (page 3.3-8).
- c.
TS Table 3.3.1.1-1, Average Power Range Monitors ALLOWABLE VALUE of FUNCTION 2.b, Neutron Flux-High (Flow Biased), page 3.3-16, referenced by LCO 3.4.1c (Recirculation Loops Operating), is revised from 0.66 W + 71.5% RTP(b) to 0.75 W + 62.0% RTP(b). Footnote (b) is revised from 0.66 W + 71.5% - 0.66 to 0.75 W + 62.0% -
0.75.
- d.
ALLOWABLE VALUE on page 3.3-51 for TS Table 3.3.6.1-1, FUNCTION 1.c., Main Steam Line Flow - High, is revised from 144% rated steam flow to 142.7% rated steam flow.
To support NRC assessment of the acceptability of the LAR in regard to the setpoint change, please provide the following for each setpoint to be added or modified:
- 1.
Setpoint Calculation Methodology: Provide documentation (including sample calculations) of the methodology used for establishing the limiting setpoint (or NSP) and the limiting acceptable values for the As-Found and As-Left setpoints as measured in periodic surveillance testing as described below. Indicate the related Analytical Limits and other limiting design values (and the sources of these values) for each setpoint.
- 2.
Safety Limit (SL)-Related Determination: Provide a statement as to whether or not the setpoint is a limiting safety system setting on which an SL has been placed as discussed in paragraph 50.36(c)(1)(ii)(A) of Title 10 of the Code of Federal Regulations (10 CFR). If a setpoint is not SL-related, explain the basis for this determination.
- 3.
For Setpoints That Are Determined To Be SL-Related: Please refer to the NRC letter to the Nuclear Energy Institute Setpoint Methods Task Force dated September 7, 2005 (ADAMS Accession No. ML052500004), which describes Setpoint-Related TS (SRTS) that are acceptable to the NRC for instrument settings associated with SL-related setpoints. Specifically: Part A of the Enclosure to the letter provides limiting condition for operations (LCO) notes to be
added to the TS, and Part B includes a checklist of the information to be provided in the TS Bases related to the proposed TS change.
- a.
Describe whether and how the SRTS suggested in the September 7, 2005, letter will be implemented. If you do not plan to adopt the suggested SRTS, then explain how you will compliance with 10 CFR 50.36 by addressing items 3b and 3c below.
- b.
As-Found Setpoint Evaluation: Describe how surveillance test results and associated TS limits are used to establish operability of the safety system.
Show that this evaluation is consistent with the assumptions and results of the setpoint calculation methodology. Discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be inoperable or operable but degraded. If the criteria for determining operability of the instrument being tested are located in a document other than the TS (e.g., plant test procedure) explain how the requirements of 10 CFR 50.36 are met.
- c.
As-Left Setpoint Control: Describe the controls employed to ensure that the instrument setpoint is, upon completion of surveillance testing, consistent with the assumptions of the associated analyses. If the controls are located in a document other than the TS (e.g. plant test procedure) explain how the requirements of 10 CFR 50.36 are met.
- 4.
For Setpoints That Are Determined To Be Non-SL-related: Describe the measures to be taken to ensure that the associated instrument channel is capable of performing its specified safety functions in accordance with applicable design requirements and associated analyses. Include in your discussion information on the controls you employ to ensure that the as left trip setting after completion of periodic surveillance is consistent with your setpoint methodology.
Also, discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be inoperable or operable but degraded. If the controls are located in a document other than the TS (e.g., plant test procedure), describe how it is ensured that the controls will be implemented.