ML20081B424

Application for Amend to License DPR-16,changing Tech Specs Re Fire Detection Instruments to Comply w/NUREG-0737 (Generic Ltr 83-36),Items II.B.1,II.B.3,II.F.1 & II.D.3.4

ML20081B424
Person / Time
Site:	Cooper
Issue date:	02/29/1984
From:	Kunck L, Kuncl L NEBRASKA PUBLIC POWER DISTRICT
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20081B427	List: ML20081B424 ML20081B429
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-2.B.3, TASK-2.D.3, TASK-2.F.1, TASK-TM GL-83-36, NLS-8400076, NUDOCS 8403090100
Download: ML20081B424 (6)

Text

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,i GENERAL 0FFICE

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NLS8400076 February 29, 1984 Office of Nuclear Reactor Regulation Operating Reactor Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention : Mr. D. B. Vassallo, Chief -

Subject:

Proposed Change No.11 to Technical Specifications Cooper Nuclear Station: 0737 NRC Docket No. 50-298, DPR-46 In accordance with the applicable provisions specified in 10CFR50, Nebraska Public Power District requests that the Technical Specifications for Cooper Nuclear Station (CNS) be revised to incorporate the miscellaneous changes listed below:

Attachment Subject 1

NUREG-0737 (Generic Letter 83-36) 2 Fire Detection Instruments 3 Editorial Change A discussion and the applicable revised Technical Specification pages are contained in each attachment. Each modification to the Technical Specifications within this proposed change has been Q-evaluated with respect to the requirements of 10CFR50.92. The results of individual evaluations are included within each attachment.

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Ox By copy of this letter and attachments the appropriate State of Nebraska Official is being notified in accordance with 10CFR50.91(b) .

oc g These changes have been reviewed by the necessary Safety e$ Review Committees and payment for a Class II amendment in the man.

amount of $1,200 is submitted, b

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l P ge 2 F:brutry 29, 1984 Should you have any questions or require additional information, please contact me.

In addition to . three signed originals, 40 copies are also submitted for your use.

Sincerely, L, G. Kuncl

' Assistant General Manager - Nuclear LGK/gmc:emz1/10 Attachments

- cc: II. E. Simmons Department of Ilecith State of Nebraska e-

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2 Pcg3 3 Ftbrutry 29, 1984 STATE OF NEBRASKA)

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L. _G. Kuncl, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Pcwer District; and that the statements contained herein are true to the best of his knowledge and belief.

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U G. Kuncl Subscribed in my presence and sworn to before me thisfpd day of  % CPinnnu , 1984.

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Attachment 1 Rev1;ed Technical Specifications for NUREG-0737 (Generic Letter 83-36)

' Revised Pages: 1, iv, 49, 65, 66, 67a 67b, 80, 82a, 87a, 227 Nebraska Public Power District requests a revision to the Technical

' Specifications to incorporate the changes due to NUREG-0737 requested under Generic Letter 83-36. A discussion of each individual item covered under 83-36 is included as follows:

1. Reactor Coolant System Vents (II.B.1,)

As the NRC. stated in Generic Letter 83-36, no changes in Technical

. Specifications are required for Boiling Water Reactors (BWR's) that do not have isolation condensers. Accordingly, no changes will be submitted

-for this item.

2. Postaccident Sampling (II.B.3)

L Page 227 of the Technical Specifications was revised to establish an administrative' program which will implement and maintain postaccident sampling capability.

3. Noble Gas Effluent Monitor (II.F.1.1)

Page 49 of the Technical Specifications .has been revised and new pages 67a, 67b, and 82a - have been added. These pages define the instrumentation and calibration requirements for the noble gas effluent monitors and also actions required when these operational limitations are not met.

4. Sampling and Analysis of Plant Effluents (II.F.1.2)  ; ,

This item was implemented on revised page 227 of the Technical '

Specifications consistent with that shown on Item 2 above.

5. Containment High-Range Monitor (II.F.1.3) ,

This item was implemented in the same manner as was Item 3 above.

6. Containment Pressure Monitor (II.T.1.4)

Pages 65, 66, and 80 are revised. These pages define the instrumentation and calibration requirements for the containment pressure monitor and also actions required when these operational limitations are not met.

7. Containment Water Level Monitor (II.F.1.5)

This item was implemented in the same manner as was Item 6 above.

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8. Cencainment Hydrogen Monitor (II.F.1.6)

In a letter from T. J. Dente to D. G. Eisenhut dated August 12, 1982,

" Interim Requirements Related to Hydrogen Control", the BWR Owners Group submitted a technical evaluation which determined that the installation of hydrogen recombiner capability is not necessary for combustible gas control at Cooper Nuclear Station. This is due to the fact that the inerted containment design is adequate for control of combustible gases without a need for recombiners. SECY 83-292 dated July 19, 1983, was written in support of this position. Concerning the Containment Hydrogen Monitor (II.F.1.6), the BWR Owners Group submitted comments in a letter from T. J. Dente to D. G. Eisenhut dated May 6,1983, in which Mr. Dente stated in Comment 9 "There is no need to monitor containment hydrogen levels during Power Operation or Startup Modes because combustible gas control is not based on control of hydrogen." Additional requirements have been proposed for hydrogen monitoring by Regulatory Guide 1.97.

Because of this fact, and in accordance with the Owners Group position (i.e., no need to monitor containment hydrogen levels), the District intends to defer implementation of this Technical Specification until the requirements of Regulatory Guide 1.97 are addressed.

9. Control Room Habitability Requirements (II.D.3.4)

In a letter from D. B. Vassallo to J. M. Pflant dated February 24, 1982, the NRC transmitted an SER which found acceptable NPPD's response to Item III.D.3.4.

The District's response was made in a letter from J. M. ,Pilant to D. G. Eisenhut dated December 30, 1980. In this communication we stated that no modification wculd be necessary to meet the intent of III.D.3.4.

In reviewing the District's CNS Technical Specifications against those contained in Generic Letter 83-36, the District feels that the present Technical Specifications meet the intent of the STS contained in 83-36.

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' EVALUATION OF TECHNICAL SPECIFICATIONS WITH RESPECT TO 10CFR50.92 The ' enclosed Technical Specification change is judged to involve no significant hazards based upon the following:

1.. 'Does the_ proposed-license amendment lavolve a significant increase in the probability or consequences of an accident previously evaluated?

Evaluation Because the proposed change imposes new limitations, and also brings the Technical Specifications into agreement w'.th the GE Standard Technical

' Specifications, it does not involve a significant increase in - the

• probability or consequences of an accident previously evaluated.

2. Does the proposed license amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Evaluation

.., Because this proposed change defines Technical Specification requirements concerning NUREG-0737 and is in conformance with the GE Standard Technical Specifications, it does not create the possibility for a new or different accident from any accident previously evaluated.

-3. Does the proposed amendment involve a significant reduction in a. margin of safety? .

Evaluation Because this proposed change adds new limitations concerning NUREG-0737 imposed changes and is in agreement with GE Standard Technical Specifications, it does not involve a significant reduction in a margin l ofi safety. ,

Additional basis for. proposed no significant hazards consideration determination:

The Commission has provided guidance concerning the application of the standards fer ' determining whether a significant hazards consideration exists by providing examples (48FR14870). The examples include: "(11) A

. change that constitutes an additional limitation, restriction, or control not presently' included in the Technical Specifications. . ."

The proposed change which adds new limitations for components added under NUREG-0737 is clearly encompassed by Example (ii).