ML12278A138
| ML12278A138 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/28/2012 |
| From: | O'Grady B J Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2012103, TAC ME7324 | |
| Download: ML12278A138 (10) | |
Text
N Nebraska Public Power District Always there when you need us 50.90 NLS2012103 September 28, 2012 U,S. Nuclear Regulatory Commission Attention:
Document Control Desk.Washington, D.C. 20555-0001
Subject:
Supplement to License Amendment Request to Revise Technical Specification 3.4.9, "RCS Pressure and Temperature (P/T) Limits" (TAC NO. ME7324)Cooper Nuclear Station, Docket No. 50-298, DPR-46
References:
- 1. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.Nuclear Regulatory Commission, dated September 10, 2012, Response to Request #2 for Additional Information Re: License Amendment Request to Revise Technical Specification 3.4.9, "RCS Pressure and Temperature (P/T) Limits" (TAC NO. ME7324) (NLS2012062)
- 2. Letter from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, to Brian J. O'Grady, Nebraska Public Power District, dated August 10, 2012, Cooper Nuclear Station -Request for Additional Information Re: License Amendment Request to Revise Technical Specification 3.4.9, "RCS Pressure and Temperature (P/T) Limits" (TAC NO. ME7324)3. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.Nuclear Regulatory Commission, dated September 22, 2011, License Amendment Request to Revise Technical Specification Pressure/Temperature Limit Curves and Surveillance Requirements (NLS2011015)
Dear Sir or Madam:
The purpose of this letter is for Nebraska Public Power District to supplement, as committed (Reference
- 1) in response to a request for information (Reference 2), the license amendment request (LAR) for the Cooper Nuclear Station (CNS) facility operating license to revise Technical Specification Pressure/Temperature (P/T) Limit Curves and Surveillance Requirements (Reference 3). This supplement revises the P/T curves previously submitted to remove consideration of instrument nozzles.CNS requests approval of the proposed amendment by March 31, 2013, which allows 6 additional months for Nuclear Regulatory Commission review. Once approved, the amendment COOPER NUCLEAR STATION P0. Box 98 / Brownville, NE 68321-0098 Telephone:
(402) 825-3811 / Fax: (402) 825-5211 www.nppd.com NLS2012103 Page 2 of 3 will be implemented within 60 days to support expiration of the 28 Effective Full Power Years limitation.
Attachment 1 provides the justification for this revision to the curves. Attachment 2 provides the revised P/T curves in clean typed format. The Enclosure contains the revised Structural Integrity Associates calculation.
No regulatory commitments are made in this supplement to the LAR.The information submitted by this supplement to the LAR does not change the conclusions or the basis of the no significant hazards consideration evaluation provided with Reference 3.If you have any questions concerning this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.I declare under penalty of perjury that the foregoing is true and correct.Executed on )-% -(date)Sincerely, Brian J. O'Gray Vice President
-Nuclear and Chief Nuclear Officer/em Attachments:
Enclosure:
- 1) Supplement to License Amendment Request to Revise Technical Specification Pressure/Temperature Limit Curves and Surveillance Requirements
- 2) Proposed Technical Specification (TS) Revisions (Re-Typed)
Calculation NEDC 07-048 CCN 5C3, Revised Pressure Temperature Curves cc: Regional Administrator w/ attachments
& enclosure USNRC -Region IV Cooper Project Manager w/ attachments
& enclosure USNRC -NRR Project Directorate IV-I Senior Resident Inspector w/ attachments
& enclosure USNRC -CNS NLS2012103 Page 3 of 3 Nebraska Health and Human Services w/ attachments
& enclosure Department of Regulation and Licensure NPG Distribution w/o attachments or enclosure CNS Records w/ attachments
& enclosure NLS2012103 Attachment 1 Page 1 of 3 Attachment 1 Supplement to License Amendment Request to Revise Technical Specification Pressure/Temperature Limit Curves and Surveillance Requirements Cooper Nuclear Station, Docket No. 50-298, DPR-46 1.0 Supplement Description
2.0 Detailed
Description
3.0 Technical
Evaluation
4.0 Regulatory
Safety Analysis 5.0 Environmental Consideration
6.0 References
NLS2012103 Attachment I Page 2 of 3 1.0 SUPPLEMENT DESCRIPTION This supplement revises the curves submitted to the Nuclear Regulatory Commission (NRC) on September 22, 2011 in a license amendment request (LAR) to amend the Cooper Nuclear Station (CNS) Facility Technical Specifications (TS) for Reactor Coolant System (RCS) pressure and temperature limits. This supplement replaces TS Figures 3.4.9-1, 3.4.9-2, and 3.4.9-3 in the LAR. As with the LAR, these curves resolve the 28 Effective Full Power Years (EFPY) limitation from Amendment 231 (which will be reached in July, 2013), and account for the 1.62% Appendix K power uprate previously approved, and for a 24-Month Operating Cycle. They differ from those in the LAR by removing consideration of instrument nozzle stresses which had been previously included.CNS requests approval of the proposed amendment by March 31, 2013 which allows 6 additional months for NRC review. Once approved, the amendment will be implemented within 60 days to support expiration of the 28 EFPY limitation.
2.0 DETAILED
DESCRIPTION 2.1 As with the LAR submitted in 2011, these curves replace the boiling water reactor 28 EFPY curves with new curves based on an RCS age of 32 EFPY, Appendix K power uprate, and a fluence evaluation performed by TransWare Enterprises Inc. and accepted by CNS using NRC-approved Radiation Analysis Modeling Application fluence methodology.
During review of the LAR, NRC staff noted Nebraska Public Power District's (NPPD's) LAR, which includes Structural Integrity Associates (SIA) calculation package 1100445.303, provides a reference to a generic Linear Elastic Fracture Mechanics (LEFM) methodology used for calculating the applied stress intensity factor values for the N 16 instrument nozzles. For CNS, the N 16 nozzles define part of the bounding beltline region P-T curves at low temperatures.
The generic LEFM methodology referenced in the LAR is currently under review by NRC staff, and NPPD was asked to provide an alternate methodology for the stated instrument nozzles. In response, NPPD committed to resubmit the curves without the analysis of the instrument nozzles, and contracted with SIA to provide the new curves using the same methodology as before, except for consideration of instrument nozzle stresses.The new curves provided in this submittal satisfy that response.
See the Enclosure to this supplement.
2.2 The other proposed changes submitted by the LAR remain valid, and are not being revised in this supplement.
NLS2012103 Attachment I Page 3 of 3 3.0 TECHNICAL EVALUATION The technical evaluation submitted by the LAR remains valid. In summary, the proposed change is technically sound and continues to maintain the same level of safety as the CNS current licensing basis.4.0 REGULATORY SAFETY ANALYSIS The regulatory safety analysis, including the No Significant Hazards Consideration Determination, submitted by the LAR remains valid. It continues to show: (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.5.0 ENVIRONMENTAL CONSIDERATION The environmental consideration submitted by the LAR remains valid. The proposed amendment, which would change a TS SR, continues to not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluent that might be released offsite, or (3) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
6.0 REFERENCES
The references identified in the LAR remain valid. A new reference is added as follows.6.12 Calculation NEDC 07-048, Configuration Change Notice to Revision 5C3, Revised Pressure Temperature Curves NLS2012103 Attachment 2 Page 1 of 4 Attachment 2 Proposed Technical Specification (TS) Revisions (Re-Typed)
Cooper Nuclear Station, Docket No. 50-298, DPR-46 Revised TS Pages 3.4-23 3.4-24 3.4-25 RCS P/T Limits 3.4.9 Cooper HeatuplCooldown, Core Not Critical Curve (Curve B), 32 EFPY 1,300 1,200 1,100-&1,000.r-j U) 900 U, U.'o 800 U.'n, 700 z I---i 600 U, U) 500 U.-----/- --- -._.itzziz
-Beltbine Region -i-i *--Bottom Head-- ---- Upper Vessel----I-i ------- --~~z~z~zz1Tz-------
-.------ -70 0 F,582 psig 70*F, 353 psig _ Ii j +/- 1 -Region 70F 31 psi 14*,33pi>70°F,82 si , L 400 300 200 100 0 0 20 40 60 80 100 120 140 160 180 200 220 240 260 280 300 320 340 MINIMUM REACTOR VESSEL METAL TEMPERATURE (OF)Figure 3.4.9-1 Pressure/Temperature Limits for Non-Nuclear Heatup or Cooldown Following Nuclear Shutdown Valid Through 32 EFPY 3.4-23 Amendment No.Cooper RCS P/T Limits 3.4.9 Cooper Pressure Test Curve (Curve A), 32 EFPY 0:3 U)0..I=-J C,)UJ I-0 I-_.1 1,300 1,200 1,100 1,000 900 800 700 600 500 F-Beltline Region--Bottom Head---Upper Vessel I F I IF 7 70F. 814 psig Ii 1 t i -i -!__70 0 F, 685 psig -Safe.... .BIo I I Tiemp> 70'F -. -----*---------------------F-g----
I ....I -I I I 400 300 200 100 0 0 20 40 60 80 100 120 140 160 180 200 220 240 260 280 300 320 340 MINIMUM REACTOR VESSEL METAL TEMPERATURE (fF)Figure 3.4.9-2 Pressure/Temperature Limits for Inservice Hydrostatic and Inservice Leakage Tests Valid Through 32 EFPY 3.4-24 Amendment No.Cooper RCS P/T Limits 3.4.9 Cooper Heatup/Cooldown, Core Critical Curve (Curve C), 32 EFPY 1,300 1,200 1,100 1,000 ,n a.--900 U)(/)wu 800 0 I.-S700 z I--9600 ILU U)500 w w IL 400 300 200 100--4 1 ..-4_t 2 _-i/i-7 4 4-----ri>> ~-7777- 7~i7777 I -~--4----,--.- t 7117k-4--- -- t---. t- -4 .-.---i----...+--
q- -I --S -I- ---4--* f- -*- I ---...+ ..f -r--" I ."!- '-' I -'---I 4--4--44--~---I--i-j*4 4 1180°F, 671 psig/- 4 4 4 4-7-4--T.
---.Safe " Operating
-t..._R _ EegaioingI
--4 77-1 77-.--------
4----- 7 -I- -'------,----
4 4-I 4 -I S998F3F, 313 psig-80F, 214psg" .Minimum Core Critical -.- -; ...Temperature:-- > 807F; " " _; i -I
- 4 0 0 20 40 60 80 100 120 140 160 180 200 220 240 260 280 300 320 340 MINIMUM REACTOR VESSEL METAL TEMPERATURE (fF)Figure 3.4.9-3 Pressure/Temperature Limits for Criticality Valid Through 32 EFPY Cooper 3.4-25 Amendment No.