ML20216J120
| ML20216J120 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/13/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1433, RTR-REGGD-01.105, RTR-REGGD-1.105 NLS980046, NUDOCS 9803230359 | |
| Download: ML20216J120 (3) | |
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P.O. BOX B L NEB SKA 68321 Nebraska Public Power District TM?"
a NLS980046 i
March 13,1998 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
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Subject:
Acceptability of General Electric Setpoint Methodology, Cooper Nuclear Station, NRC Docket 50-298, DPR-46 i
Reference:
1.
Letter to U.S. Nuclear Regulatory Commission from G. R. Horn, Nebraska Public Power District, dated March 27,1997, " Proposed Changed to CNS Technical Specifications, Conversion to Improved Standard Technical
)
Specifications" 2.
Letter from Bruce A Boger, U. S. Nuclear Regulatory Commission, j
Director, Division of Reactor Controls and Human Factors, to Robert A, Pinelli, Chairman, Boiling Water Reactor Owners' Group, " Revision to Safety Evaluation Report, NEDC-31336, Instrument Setpoint j
Methodology" By letter dated March 27,1997 (Reference 1), Nebraska Public Power District (District) requested an amendment to License DPR-46 to convert to Improved Technical Specifications (ITS) at Cooper Nuclear Station (CNS), consistent with NUREG-1433, Revision 1, " Standard Technical Specifications for General Electric Plants, BWR4." Calibration frequencies and allowable values in the ITS were developed in accordance with NUREG-1433. Allowable values for the specified calibration frequencies are based upon the use of the General Electric (GE)
Instrument Setpoint Methodology (NEDC-31336), which conforms to the guidelines of Regulatory Guide 1.105, Revision 2 and ISA Standard S.67.04,1982.
The use of this methodology is common and standard for Boiling Water Reactors (BWRs). It has been approved for use at other BWR facilities in support ofITS conversion and calibration extension programs. The revised Safety Evaluation Report (SER), Reference 2, provided to the~
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Boiling Water Reactor Owners' Group (BWROG) indicated that NEDC-31336 was an important reference document for understanding how GE selects instrumentation setpoints. However, the llll4l!l!!!lllllll!lll.llllllllllll
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NLS980046 March 13,1998 4
Page 2 SER als'o states that the topical report is not to be used by any plant to validate its individual I
setpoints. CNS has performed plant specific analyses using the GE setpoint methodology to incorporate CNS plant information and operational considerations to develop the ITS allowable values. The CNS application of the setpoint methodt ;gy is consistent with the intent of the Topical Report and the Nuclear Regulatory Commission (NRC) SER.
It was stated.in the cover letter for the revised SER that, should the NRC's acceptance criteria or regulations change so that conclusions as to the acceptability of NEDC-31336 are no longer valid, the BWROG and/or the applicants referencing this topical report will be expected to revise and l
resubmit their respective documentation or submit justification for the continued applicability of the topical report without revision of the documentation. Since no notification of change in acceptance criteria or regulations has been indicated, CNS believes that the GE topical report, NEDC-31336, is a valid reference and a valid methodology for the calculation of allowable values for the ITS conversion.
Setpoint calculations are performed at CNS in accordance with procedure 3.26.3. The methodology presented in this procedure is based upon the General Electric Instrument Setpoint Methodology of NEDC-31336. In addition, this procedure is used in conjunction with General Electric Document EDE-38-1090, Setpoint Calculation Guidelines for the Cooper Nuclear Station.
2 The District adopted the GE setpoint methodology in the 1990 time frame and has verified the acceptability of Technical Specification values based on this methodology. Since this is, and has been, the CNS methodology of record for several years, this methodology is consistent with earlier appreaches and maintains the instrument design basis. Application of this methodology to the ITS conversion would not only be expected, but required.
Sincerely, L__
1.
iles ice siden ofNuclear Energy
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Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution j
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l ATTACHNENT 3 LIST OF NRC COMMITMENTS l
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Correspondence No: NLS980046 The following table identifies those actions committed to by the District in this i
document. Any other actions discussed in the submittal represent intended or j
planned actions by the District.
They are described to the NRC for the NRC's i
information and are not regulatory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
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COMMITTED DATE
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COMMITMENT OR OUTAGE l
None I
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l PROCEDURE NUMBER 0.42 l
REVISION NUMBER 5 l
PAGE 9 OF 13 l
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