ML20095B856
| ML20095B856 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/04/1995 |
| From: | Mueller J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 GL-94-02, GL-94-2, NLS950213, NUDOCS 9512110237 | |
| Download: ML20095B856 (3) | |
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COOPER NUCLEAR STATION e
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<NLS950213 December 4,1995 -
I U. S.Nublear Regulatory Commission
. Attention: Document Control Desk 1
Washington, D.C. 20555-0001-l z
Subject:
. Cooper Nuclear Station Compliance.with NEDO-31558, " Position oniNRC '
l Regulatory Guide.l.97, Revision 3, Requirements for' Post-Accident Neutron-j
. Monitoring System." :.
1 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
References:
1)-
NEDO-31558, dated March,1988," Position on NRC Regulatory Guide 1.97,
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Revision 3, Requirements for Post-Accident Neutron Monitoring System."
2)
Letter fmm G. R. Hom (NPPD) to NRC dated June 7,1993, " Cooper Nuclear Station Comphance with NEDO-31558."
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3)
USNRC Generic Letter 94-02, dated July 11,1994, "Long-Term Solutions and Upgrade'ofInterim' Operating Recommendations for Thermal-Hydraulic Instabilities in Boiling Wa' er Reactors."
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. Gentlemen:
- The Nebraska Public Power District (District) plans to defer until the next scheduled refueling outage, a commitment made in Reference 2 conceming modification of the neutron monitoring l
. system (NMS) at Cooper Nuclear Station (CNS). The District will defer this commitment in order j
s to coordinate these modifications with planned changes to the NMS to address thermal-hydraulic l
in' tabilities in accordance with GL 94-02 (Reference 3).
s l Based on the difficulty in meeting Regulatory Guide (RG) 1.97 requirements for Boiling. Water l
Reactor NMSs, the BWR Owners Group (BWROG) evaluated operational requirements for BWR NMSs for a broad spectrum of events and developed attemative NMS design requirements to meet the intent of RG l.97c This evaluation is documented in NEDO-31558 (Reference 1). By letter i
dated June 7,1993 (Reference'2), the District committed to take further actions prior to startup from j
' the next scheduled CNS refueling ~ outage'(RE16) to ensure conformance with NEDO-31558 criteria.
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conceming the NMS power sources.
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Page 2 of 2 i
In accordance with the District's plans to modify the NMS during the next scheduled refueling outage to address thermal-hydraulic instabilities in compliance with GL 94-02, it will be more flicient to coordinate any necessary NMS hardware changes required for NEDO-31558 compliance e
j with that effort. Modifications for compliance with CL 94-02 and any necessary for compliance with NEDO-31558 criteria are planned for implementation during the 1997 refueling outage (RE17).
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Deferring these actions until the next refueling outage will not have a significant impact on plant i
safety. Based on the BWROG evaluation documented in NEDO-31558, it was determined that post-accident neutron monitoring, while useful to the operator, is not essential for assuring post-4 accident plant safety is maintained for any of the events analyzed. It was also concluded that for i
BWRs, the Rod Position Indication System provides the primary verification for determining plant l
. shutdown. Finally, NRC approved Emergency Operating Procedures, to which the operators are trained, provide guidance on ATWS mitigation with or without the availability of the APRMs for l
power monitormg.
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The District defers these commitments based on the efTectiveness ofincorporating it with GL 94-02 l
l changes and the absence of a significant safety concem.
The District will implement all of the modifications determined as necessary for the NMS to comply l
s with GL 94-02 and NEDO-31558 during the next scheduled refueling outage (RE17).
Should you have any questions conceming this matter, please contact my office.
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i John IL Mueller Site Manager l
Cooper Nuclear Station
.CCT cc:
Recional Administrator i
USNRC Region IV j
Snior ResidentInspector (JSNRC - Cooper Nuclear Station Senior Project Manager USNRC - NRR Project Directorate IV-1 NPG Distribution i
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LIST OF NRC COMMITMENTS l ATTACHMENT 3, l.
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Correspondence No: NLS950213 -
The following table' identifies those actions committed to by the District in this document. Any.
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. other actions ' discussed in the submittal represent intended or planned actions by the District. They i
. are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document i
or any associated regulatory commitments.
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's COMMfITED DATE -
' COMMITMENT OR OUTAGE The District will implement all of the modifications determined as necessary for the NMS to comply with GL 94-02 and NEDO-31558.
Refueling Outage 17 -
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PROCEDURE NUMBER 0.42 REVISION NUMBER 0.2 PAGE 10 OF 16 4
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