ML15021A249

NRR E-mail Capture - Cooper Nuclear Station - RAIs for LAR Associated with Moving LHGR and Single Loop Operation LHGR Limit from TRM to TS

ML15021A249
Person / Time
Site:	Cooper
Issue date:	01/21/2015
From:	Siva Lingam Plant Licensing Branch IV
To:	Shaw J Nebraska Public Power District (NPPD)
References
TAC MF4485
Download: ML15021A249 (4)

Text

NRR-PMDAPEm Resource From: Lingam, Siva Sent: Wednesday, January 21, 2015 9:13 AM To: jdshaw@nppd.com Cc: Oesterle, Eric; Haskell, Russell; Forsaty, Fred; Snyder, Pete

Subject:

Cooper Nuclear Station - RAIs for LAR Associated with Moving LHGR and Single Loop Operation LHGR Limit from TRM to TS (TAC No. MF4485)

By letter dated July 17, 2014 (Agencywide Documents Access and Management System Accession No. ML14203A045), Nebraska Public Power District (the licensee) submitted a License Amendment Request (LAR) for Cooper Nuclear Station. The proposed LAR would move Linear Heat Generation Rate (LHGR) and Single Loop Operation LHGR Limit from Technical Requirements Manual (TRM) to Technical Specifications (TSs) for cycle 23. Please note the following official requests for additional information (RAIs), and provide your responses within 30 days from the date of this e-mail.

RAI-1

LAR Section 2.0 provides a discussion describing the changes to the TS affected by the LAR.

a. In LAR Section 2.1 it is stated that the changes would revise the requirements for the Core Operating Limit Report (COLR). Provide a proposed markup for the changes to the COLR that would result from approval of this LAR.

b. In LAR Section 2.2 it is stated that the LHGR is presently monitored and controlled per the TRM.

Provide a proposed markup for the changes to the TRM that would result from approval of this LAR.

RAI-2

LAR Section 2.2 states that the implementation of the proposed changes is consequential to the use of PANAC11 in Cycle 23. Provide a reference to the approved methodology employed to accomplish the analysis supplied to support the change.

RAI-3

LAR Section 3.3 describes the use of both 1D and 3D Boiling Water Reactor (BWR) simulator codes without identifying them by name or reference. Provide citable references for these codes.

RAI-4

LAR Section 3.3 states that the MAPFAC multiplier is contained in the COLR. However, the only COLR information provided is TS 5.6.5, which does not contain such information. Provide all portions of the COLR that are applicable to this LAR.

1

RAI-5

LAR Section 3.5 states that revising TS 1.1, TS 3.2, TS 3.4, TS 3.7, and TS 5.6 to add the LHGR limits has no impact on the Updated Safety Analysis Report (USAR) accident analysis and ensures that the assumptions in the USAR accident analyses remain valid. However, the reviewers are unable to confirm this since the LAR does not include the relevant USAR information.

a. Provide a proposed markup for any changes to the USAR that would result from approval of this LAR.

b. Provide the portion of the USAR that contains the assumptions cited.

c. Include any applicable references that will be needed to review any additional material.

RAI-6

LAR Section 4.3 provides the No Significant Safety Hazards Consideration.

a. It states that the proposed change does not modify the limits, change the assumptions for the accident analysis, or change operation of the station. However, there are no references or analyses provided to support this assertion. Provide the references and technical basis to support this assertion.

b. The analysis does not state whether the accident analysis was performed again and if it was, whether that analysis shows any reduction to the margin between the limits and the as-calculated values (including the uncertainties). Clarify this matter.

RAI-7

The following table illustrates those elements of the TS that are altered by the proposed changes. Please confirm that there are no changes required to Limiting Conditions for Operation (LCO) 3.2.1, Surveillance Requirement (SR) 3.4.1, and SR 3.7.7.

LCO Supplied SR Supplied Bases Supplied Not supplied Not supplied 3.2.1 3.2.3 LHGR 3.2.3.1 3.2.3 3.4.1 Loops Not supplied 3.4.1 3.7.7 Bypass Not supplied 3.7.7 5.6.5 COLR n/a n/a

RAI-8

Provide references missing in the Attachment 4 Sections B.3.4.1 and B.3.7.7.

RAI-9 , B 3.2.3 LCO describes adjustments to the LHGR limit using the smaller of either LHGRFACf, LHGRFACp, and 0.75, where 0.75 has been determined by a specific single recirculation loop analysis.

However, this methodology then references both NEDO-24258, "Cooper Nuclear Station Single Loop Operation," May 1980 and NEDC-32687P, Revision 1, "Cooper Nuclear Station SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis, II March 1997.

a. The Nuclear Regulatory Commission (NRC) staff is uncertain whether one or both of these references provide the underlying methodology and if both are involved how they are used in combination. Please clarify.

b. Indicate whether the use of these reports has been approved by the NRC.

2

RAI-10 , B 3.2.1 Applicable Safety Analysis, Paragraph 2, states that APLHGR limits are developed as a function of exposure and the various operating core flow and power states using methods described in NEDO-24258. "Cooper Nuclear Station Single-loop Operation," May 1980 and NEDC-32914P, Maximum Extended load Line Limit and Increased Core Flow for Cooper Nuclear Station Revision 0, January 2000.

a. The NRC staff is uncertain whether one or both of these references provides the underlying methodology and if both are involved how they are used in combination.

Pease clarify.

b. Indicate whether the use of these reports has been approved by the NRC.

The above RAIs were sent to you as draft on December 9, 2014, and you replied this morning (January 21, 2015) that you dont need any clarification call.

Siva P. Lingam U.S. Nuclear Regulatory Commission Project Manager (NRR/DORL/LPL4-1)

Cooper Nuclear Station Diablo Canyon Nuclear Power Plant Location: O8-D5; Mail Stop: O8-B3 Telephone: 301-415-1564; Fax: 301-415-1222 E-mail address: siva.lingam@nrc.gov 3

Hearing Identifier: NRR_PMDA Email Number: 1823 Mail Envelope Properties (Siva.Lingam@nrc.gov20150121091200)

Subject:

Cooper Nuclear Station - RAIs for LAR Associated with Moving LHGR and Single Loop Operation LHGR Limit from TRM to TS (TAC No. MF4485)

Sent Date: 1/21/2015 9:12:53 AM Received Date: 1/21/2015 9:12:00 AM From: Lingam, Siva Created By: Siva.Lingam@nrc.gov Recipients:

"Oesterle, Eric" <Eric.Oesterle@nrc.gov>

Tracking Status: None "Haskell, Russell" <Russell.Haskell@nrc.gov>

Tracking Status: None "Forsaty, Fred" <Fred.Forsaty@nrc.gov>

Tracking Status: None "Snyder, Pete" <Pete.Snyder@nrc.gov>

Tracking Status: None "jdshaw@nppd.com" <jdshaw@nppd.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 5897 1/21/2015 9:12:00 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: