ML16252A223

Response to NRC Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications - Safety Limit Minimum Critical Power Ratio

ML16252A223
Person / Time
Site:	Cooper
Issue date:	08/29/2016
From:	Limpias O Nebraska Public Power District (NPPD)
To:	Document Control Desk
References
Download: ML16252A223 (4)

Text

{{#Wiki_filter:H Nebraska Public Power District Always there when you need us NLS2016055 August 29, 2016 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Response to Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications - Safety Limit Minimum Critical Po:wer Ratio Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46

References:

1. Email from Thomas Wengert, U.S. Nuclear Regulatory Commission, to Jim Shaw, Nebraska Public Power District, dated August 18, 2016, "Cooper Nuclear Station - Request for Additional Information Regarding TS Section 2.0, "Safety Limits" (CAC No. MF7605)"

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

Nuclear Regulatory Commission, dated April 21, 2016, "License Amendment Request to Revise Technical Specifications - Safety Limit Minimum Critical Power Ratio"

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District to respond to the Nuclear Regulatory Commission's Request for Additional Information (RAI) (Reference 1) related to the Cooper Nuclear Station "License Amendment Request to Revise Technical Specifications -

• • Safety Limit Minimum Critical Power Ratio" (Reference 2).

The response to the RAI is provided in the attachment to this letter. This letter does not contain any new regulatory commitments. If you have any questions concerning this matter, please contact Jim Shaw, Licensing Manager, at (402) 825-2788.

• COOPER NUCLEAR STATION P.O. Box 98 /Brownville, NE 68321-0098 Telephone: (402) 825-3817 /Fax: (402) 825-5211 www.hppd.com

v NLS2016055 Page 2 of2 I declare under penalty of perjury that the foregoing is true and correct. Executed on: __B------1-{_z_c:i----4(_1_~--- (Date) 0 . Limpias Vice President - Nuclear and Chief Nuclear Officer

 /dv

Attachment:

Response to Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications - Safety Limit Minimum Critical Power Ratio cc: Regional Administrator w/ attachment USNRC - Region IV Cooper Project Manager w/ attachment USNRC - NRR Plant Licensing Branch IV-2 Senior Resident Inspector w/ attachment USNRC-CNS NPG Distribution w/o attachment CNS Records w/ attachment

NLS2016055 Attachment Page 1 of2 Attachment Response to Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications - Safety Limit Minimum Critical Power Ratio Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 The Nuclear Regulatory Commission Request for Additional Information (RAI) regarding the License Amendment Request (LAR) to revise Technical Specifications - Safety Limit~Minimum Critical Power Ratio (SLMCPR) is shown in italics. The Nebraska Public Power District (NPPD) response to the request is.shown in normal font. , "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR- Cooper Nuclear Station Cycle 30, "to the LAR contained the relevant analysis methodologies used by GNF to perform the cycle-specific SLMCPR analysis. The GNF report stated the following methodologies were used to perform this analysis:

• NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR II)" (Reference 1)
• NEDC-32601P-A, "Methodology and Uncertainties for Safety Limit MCPR Evaluations,"

August 1999. (Reference 2)

• NEDE-10958-PA, "General Electric Thermal Analysis Basis Data, Correlation and Design Application," January 1977. (Reference 3)
• NEDC-32505P-A, "R-Factor Calculation Method for GEl 1, GEl 2 and GEl 3 Fuel,"

Revision 1, July 1999. (Reference 4) The April 21, 2016, LAR lists the following methodologies as the applicable methods used:

• NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," (Revision specified in the COLR)
• NEDE-23785-1-P-A, "The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident," Volume Ill Revision 1, October 1984.
• NED0-31960 and NED0-31960 Supplement 1, "BWR Owner's Group Long Term Stability Solutions Licensing Methodology" (the approved Revision at the time the reload analysis is performed)

The NRC staffagrees that the first listed methodology (NEDE-24011) is appropriate for the SLMCPR analysis. However, the NRC staffdoes not believe the other two methodologies listed in the LAR are related to the SLMCPR analysis. Please confirm that the GNF report is correct and verifY that the methodologies listed in the GNF report were the methodologies used for the SLMCPR analysis.

"' NLS2016055 Attachment Page 2 of2 NPPD Response NPPD has confirmed that the following two methodologies which were referenced in the April 21, 2016, LAR are not associated with the determination of the SLMCPR for Cycle 30.

• NEDE-23785-1-P-A, "The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident," Volume III, Revision 1, October 1984 o This methodology is associated in determining the cycle specific 10CFR50.46 requirements during a Loss-of-Coolant Accident event and does not impact the determination of SLMCPR.
• NED0-31960 and NED0-31960 Supplement 1, "BWR Owner's Group Long-Term Stability Solutions Licensing Methodology" (the approved Revision at the time the reload analysis is performed) o This methodology is used in determining the cycle specific stability related parameters during a stability event and does not impact the determination of SLMCPR.

The correct methodologies which were used to determine the Cycle 30 SLMCPR are the four that were referenced in Section 3.0 of the Global Nuclear Fuel Report OOON6035-Rl-NP which was previously included in the April 21, 2016, LAR.

• Global Nuclear Fuel, "General Electric Standard Application for Reactor Fuel," NEDE-24011-P-A, Revision 22, November 2015 (which is specified in the Cycle 30 COLR).
• General Electric Nuclear Energy, "Methodology and Uncertainties for Safety Limit
• MCPR Evaluations," NEDC-32601P-A, August 1999.
• General Electric Company, "General Electric Thermal Analysis Basis Data, Correlation and Design Application," NEDE-10958-P A, January 1977.
• General Electric Nuclear Energy, "R-Factor Calculation Method for GEl 1, GE12 and GE13 Fuel," NEDC-32505P-A Revision 1, July 1999.}}