NLS2004137, Supplemental Response to Request for Additional Information Regarding Revision of Technical Specification Surveillance Requirement 3.3.2.1.4 and Table 3.3.2.1-1

Supplemental Response to Request for Additional Information Regarding Revision of Technical Specification Surveillance Requirement 3.3.2.1.4 and Table 3.3.2.1-1

ML043140195
Person / Time
Site:	Cooper
Issue date:	11/05/2004
From:	Edington R Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2004137
Download: ML043140195 (4)

Text

N Nebraska Public Power District Always there when you need us NLS2004137 November 5, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

Subject:

Supplemental Response to Request for Additional Infonnation Regarding Revision of Technical Specification Surveillance Requirement 3.3.2.1.4 and Table 3.3.2.1-1 Cooper Nuclear Station, Docket 50-298, DPR-46

Reference:

I. Letter to R. K. Edington, Nebraska Public Power District, from M. C.

Honchiarik, U.S. Nuclear Regulatory Commission, dated August 13, 2004, "Request for Additional Information Regarding Revision of Technical Specification Surveillance Requirement 3.3.2.1.4 and Table 3.3.2.1 -I (TAC No. MC0629)"

2. Letter from R. K. Edington, Nebraska Public Power District, to U. S.

Nuclear Regulatory Commission dated March 9, 2004, "Response to Request for Additional Information Regarding Licensing Amendment Request to Revise Technical Specifications (TS) Surveillance Requirements and TS Table for Mathematical Symbols and Use of Allowable Values in the Place of Analytical Limits" (NLS2004006)

The purpose of this letter is for the Nebraska Public Power District (NPPD) to submit to the Nuclear Regulatory Commission (NRC) the response to the Request for Additional Information (RAI) provided in Reference 1. This RAI requested additional information regarding the previously submitted RAI response of Reference 2. The information provided by this response was discussed with the NRC staff during a telephone conference conducted on October 19, 2004.

This RAI response is limited to supplying information to assist the NRC in completing the license amendment review and does not change the conclusion of the original No Significant Hazards Consideration. The response is attached.

If you have any questions regarding this matter please call Paul Fleming, Licensing Manager, at (402) 825-2774.

4(0 COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2004 137 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

4:2 Executed on: l

~iate)j o5__

Randall Edington Vice President Nuclear and Chief Nuclear Officer

/c1b Attachment cc: Regional Administrator w/attachment USNRC - Region IV Senior Project Manager wv/attachment USNRC - NRR Project Directorate IV-I Senior Resident Inspector %v/attachment USNRC Nebraska Health and Human Services W/attachment Department of Regulation and Licensure NPG Distribution w/attachment Records Wvattachment

NLS2004137 Attachment Page I of I Supplemental Response to Request for Additional Information Regarding Revision of Technical Specification Surveillance Requirement 3.3.2.1.4 and Table 3.3.2.1-1 Cooper Nuclear Station, Docket 50-298, DPR-46 NRC Request The response to question I stated: "Thle calculation Conclusion Section lists a set ofpernissible rod block valtes for AL, A V and OperatingSetpoint, based on different MCPR [minimumu critical pow'er ratio] limits... Therefore, tihe setpointsfor tihe various regions were selected based on a MCPR Limit of 1.30... " How does the NPPDjustifr using wt'hat appearsto be a slightl~y less conseimvative value of AMCPR?

NPPD Response This request refers to Question I of Reference 2. The NRC approved use of the Extended Load Line Limit and ARTS Improvement Program Analyses for Cooper Nuclear Station Cycle 14, NEDC-31892P, Rev I, May 1991 by Amendment 151 dated November 29, 1991.

Section 5.5 of Extended Load Line Limit and ARTS Improvement Program Analyses for Cooper Nuclear Station Cycle 14, (NEDC-31892P, Rev 1, DRF B13-01512 Dated May 1991) states in part:

Any set of RBM [Rod Block Monitor] setpoints with a corresponding OLMCPR

[Operating Limit Minimum Critical Power Ratio] equal to or less than that of the limiting plant OLMCPR based on the other transient results can be utilized. The higher RBM setpoints (with a higher OLMCPR value) will afford more control rod movement flexibility without unnecessary alarms and rod blocks.

This statement means that selection of the RBM setpoint based on the lower MCPR value is conservative. The trip setpoint decreases as the MCPR value decreases. A lower value of MCPR is closer to the safety limit. Operationally, this means the RBM upscale trip will occur and block rod movement at a lower power level. The example discussed in the response to Question I of Reference 2 assumes a 1.32 MCPR value. The trip setpoint based on a MCPR of 1.30 will initiate a rod block at a lower power level than a trip setpoint based on the Rod Withdrawal Error (RWE) MCPR of 1.32, thereby, resulting in a smaller decrease in MCPR during an RWE event (i.e., more margin to the safety limit).

.,-l- ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS0 I Correspondence Number: NLS2004137 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 24l