NLS2004119, License Amendment 178 Clarification

License Amendment 178 Clarification

ML042650386
Person / Time
Site:	Cooper
Issue date:	09/14/2004
From:	Fleming P Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2004119
Download: ML042650386 (3)

Text

Nebraska Public Power District Always there when you need us NLS2004119 September 14, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

License Amendment 178 Clarification Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46

Reference:

1) Letter from G. R. Horn (NPPD) to USNRC dated March 27, 1997, "Proposed Change to CNS Technical Specifications, Conversion to Improved Standard Technical Specifications" (NLS970002)

2) Letter from J. H. Swailes (NPPD) to USNRC dated May 6, 1998, "Proposed Change to CNS Technical Specifications, Revision A, Conversion to Improved Standard Technical Specifications" (NLS980065)

3) Letter from J. N. Donohew (USNRC) to G. R. Horn (NPPD) dated July 31, 1998, "Conversion to Improved Technical Specifications for the Cooper Nuclear Station - Amendment 178 to Facility Operating License No. DPR-46" The purpose of this letter is to provide clarification on the relocation of a previous Custom Technical Specification (CTS) requirement to a licensee-controlled document. Per References 1 and 2, Nebraska Public Power District (NPPD) indicated its intent to relocate CTS Surveillance Requirement (SR) 4.5.A.3.f to the Updated Safety Analysis Report (USAR). This SR required an air test to be performed on the drywell and torus headers and nozzles once every five years.

However, the Safety Evaluation issued by the Nuclear Regulatory Commission (NRC) in Reference 3 identified this as a relocation to the Technical Requirements Manual (TRM). No documentation has been identified that indicates there was a request on either the part of the NRC or NPPD to make this change. NPPD relocated the subject requirement to the USAR. The impact of relocating this requirement to the USAR versus the TRM has no safety significance.

The governing regulation for changing both the USAR and TRM is 10CFR50.59, therefore either location provides the desired regulatory controls. Any future changes to this USAR requirement will be made in accordance with IOCFR50.59.

COOPERNUCLEARSTATION P.O. Box 98/ Brownville, NE 68321-0098 po-o f Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS20041 19 Page 2 of 2 If you have any questions regarding this matter, please contact me at (402)-825-2774.

Sincerely, aulV Fern <

Licensing Manag

/lb cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC - Cooper Nuclear Station NPG Distribution Records

i ATTACHMENT 3 LIST OF REGULATORY COMMITMENTSl Correspondence Number: NLS2004119 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing & Regulatory Affairs Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE None I PROCEDURE 0.42 l REVISION 15 l PAGE 18 OF 24