NLS2015086, Response to Nuclear Regulatory Commission Additional Requests for Additional Information for License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Makeup Water

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Response to Nuclear Regulatory Commission Additional Requests for Additional Information for License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Makeup Water
ML15202A127
Person / Time
Site: Cooper Entergy icon.png
Issue date: 07/13/2015
From: Limpias O
Nebraska Public Power District (NPPD)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2015086
Download: ML15202A127 (4)


Text

Nebraska Public Power District Always ther~e when you need us NLS201 5086 July 13, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Response to Nuclear Regulatory Commission Additional Requests for Additional Information for License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Makeup Water Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1.

Email from Siva Lingam, U.S. Nuclear Regulatory Commission, to Jim Shaw, Nebraska Public Power District, dated June 29, 2015, "Cooper -

Additional RAIs Resulting From NPPD RAI Responses for LAR Associated with Deleting Condensate Storage Tank as an Alternate Source of Makeup Water (TAC No. MF47 16)"

2.

Letter from Oscar A. Limpias, Nebraska Public Power District, to the U.S.

Nuclear Regulatory Commission, dated August 26, 2014, "License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Makeup Water" (MLl14246A2 03)

3.

Letter from Oscar A. Limpias, Nebraska Public Power District, to the U.S.

Nuclear Regulatory Commission, dated February 25, 2015, "Response to Nuclear Regulatory Commission Requests for Additional Information for License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Make-Up Water" (ML15062A037)

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District to respond to the Nuclear Regulatory Commission's Requests for Additional Information (RAI) (Reference 1) related to the Cooper Nuclear Station "License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Makeup Water" (Reference 2) and "Response to Nuclear Regulatory Commission Requests for Additional Information for License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Make-Up Water" (Reference 3).

The response to the specific RAI questions is provided in the attachment to this letter.

This letter does not contain any new regulatory commitments.

COOPER NUCLEAR STATION

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P.O. Box 98 / Brownville, NE 68321-0098 Tele phone: (402) 825-3811 / Fax: (402) 825-5211 w

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NLS20 15086 Page 2 of 2 If you have any questions concerning this matter, please contact Jim Shaw, Licensing Manager, at (402) 825-2788.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on (Date)

(@rA. Limpias

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Vice President - Nuclear and Chief Nuclear Officer

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Attachment:

Response to Nuclear Regulatory Commission Additional Requests for Additional Information for License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Makeup Water cc:

Regional Administrator w/ attachment UJSNRC - Region IV Cooper Project Manager w/ attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ attachment UJSNRC - CNS NPG Distribution w/o attachment CNS Records wh/attachment

NLS2015086 Attachment Page 1 of 2 Attachment Response to Nuclear Regulatory Commission Additional Requests for Additional Information for License Amendment Request to Delete Condensate Storage Tank as an Alternate Source of Makeup Water Cooper Nuclear Station, Docket No. 50-298, DPR-46 The Nuclear Regulatory Commission (NRC) additional requests for additional information (RAI) regarding the License Amendment Request (LAR) to delete the Condensate Storage Tank (CST) as an Alternate Source of Makeup water are shown in italics. The Nebraska Public Power District (NPPD) response to the requests is shown in normal font.

RAI-]

With the removal of option 'b' from TS surveillance requirement 3.5.2.1, what changes will be made to Emergency Operating Procedure 5.8.14, 'Suppression Pool Make Up Systems,' or other procedures?

NPPD Response Procedure 5.8.14 provides makeup to the suppression pool from the CST and other sources.

Removal of option b from Technical Specifications does not affect providing makeup to the suppression pool using Procedure 5.8.14; therefore Procedure 5.8.14 does not require any changes.

Removal of option b from Technical Specifications will affect two other procedures. Procedure 2.2.9, Core Spray (CS) System, Revision 75, and 2.2.69.1, Residual Heat Removal (RHR) Low Pressure Coolant Injection (LPCI) Mode, Revision 26, were revised to specify that RHR and CS are inoperable when the pump's suction is aligned to CST A.

RAI-2. 1 Ident~ify any operator actions that will be changed, deleted, or added in support of this LAR? If actions will be changed or added, will any of these actions be time critical? If yes, discuss.

NPPD Response This LAR removes an option to align RHR and CS suctions to CST A and remain OPERABLE.

This option was used infrequently and only while the plant was shutdown. The procedures that contain this guidance are still in place but have been revised to specify that RHR and CS are inoperable when their suctions are aligned to the CST. No time critical operator actions are involved.

NLS20 15086 Attachment Page 2 of 2 RAI-2.2 Identify any affected procedures by number, title, revision, and a brief summary of the change(s) necessary to support this LAR.

NPPD Response Procedure 2.2.9, CS System, Revision 75, and 2.2.69.1, RUR LPCI MODE, Revision 26, were revised to specify that RHR and CS are inoperable when their suctions are aligned to the CST.

RAI-2. 3 Identfify any changes to training that are required to support this LAR.

NPPD Response As part of the license amendment implementation, the training lesson plans for CS and RHR systems will be revised to remove reference to operability when the system is aligned to take suction from the CST. Also, the lesson plan for Technical Specifications Section 3.5 will be revised to remove the reference to CST water level >14 feet, taking credit for CST suction during Operations with the Potential to Drain the Reactor Vessel, and reference to the CST as a suction path for operability.

RAJ-2. 4 Will any changes to the control room displays, controls, alarms, or annunciators, or the Safety Parameter Display System be required to support this LAR?

NPPD Response None required. This alignment is not mimicked on any Control Room display, has no controls in the Control Room, is not alarmed in the Control Room, and is not in the Safety Parameter Display System.

RAI-2. 5 Will validation of the feasibility and reliability of new or changed operator actions be performed? If not, why not?

NPPD Response No, no operator actions were changed.