NLS2010100, Revision to License Renewal Commitment
| ML103220098 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/15/2010 |
| From: | O'Grady B Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2010100 | |
| Download: ML103220098 (5) | |
Text
N Nebraska Public Power District Always there when you need us 54.21(b)
NLS2010100 November 15, 2010 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Revision to License Renewal Commitment Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
Letter from Stewart B. Minahan, Nebraska Public Power District, to U.S. Nuclear Regulatory Commission, dated September 24, 2008, "License Renewal Application" (NLS2008071)
Dear Sir or Madam:
The purpose of this letter is for the Nebiaska Public Power District to provide a revised Cooper Nuclear Station (CNS) License Renewal commitment. In a conference call conducted on November 10, 2010, the Nuclear Regulatory Commission (NRC) requested that an additional commitment be made regarding the Fatigue Monitoring Program described in the referenced License Renewal Application (LRA). This commitment is reflected in the attached LRA changes as a revision to Commitment Number NLS2008071-08.
Should you have any questions regarding this submittal, please contact David Bremer, License Renewal Project Manager, at (402) 825-5673.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on I"//!*!,.,/o (Datej Sincerely,
.4-_
Vice President - Nuclear and Chief Nuclear Officer
/wv
,4154~
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2010100 Page 2 of 2 Attachment cc:
Regional Administrator w/Attachment USNRC - Region IV Cooper Project Manager w/Attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/Attachment.
USNRC - CNS Nebraska Health and Human Services w/Attachment Department of Regulation and Licensure NPG Distribution w/Attachment CNS Records w/Attachment
NLS2010100 Attachment Page 1 of 2 Attachment Revision to License Renewal Commitment Cooper Nuclear Station, Docket No. 50-298, DPR-46 In a conference call conducted on November 10, 2010, the Nuclear Regulatory Commission (NRC) requested a commitment to ensure that the most limiting location was evaluated to assess the affects of the reactor coolant environment on component metal fatigue. NPPD has provided that commitment below in a revision to Commitment NLS2008071-08, Revision 2. The changes are presented in underline/strikeout format.'
I1.
LRA Section A.1.1.15 is revised to read:
"The Fatigue Monitoring Program will be enhanced as follows:
" Consideration of the effect of the reactor water environment will be accomplished through implementation of one or more of the following options for the reactor vessel shell and lower head, feedwater nozzles, core spray nozzles and RHR pipe transition. In addition, NPPD will review design basis ASME Class 1 component fatigue evaluations to determine whether the CNS locations that have been evaluated for the effects of the reactor coolant environment on fatigue include the limiting component within the reactor coolant pressure boundary. If a more limiting component is identified, NPPD will determine the effects of the reactor coolant environment on its fatigue usage in accordance with the following.
(1) Update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case). NPPD will use NUREG/CR-6909 when determining the effects of the reactor coolant environment on the fatigue life of Alloy 600 or other nickel alloy components.
(2) Repair or replace the affected locations before exceeding a CUF of 1.0.
The CNS Fatigue Monitoring Program will be enhanced to require the recording of each transient associated with the actuation of a safety/relief valve (SRV).
Enhancements will be implemented at least two years prior to entering the period of extended operation."
The changes shown are made against Revision 2 of this commitment submitted inNLS2010044 on April 28, 2010 (ADAMS Accession Number ML101250530).
NLS2010100 Attachment Page 2 of 2 Basis for change: Change requested in a conference call with the NRC Staff on November 10, 2010.
- 2.
LRA Section B.1.15 is revised to read2:
Elements Affected Enhancement 2.
4.
6.
7.
Preventive Actions Detection of Aging Effects Acceptance Criteria Corrective Actions Consideration of the effect of the reactor water environment will be accomplished through implementation of one or more of the following options for the reactor vessel shell and lower head, feedwater nozzles, core spray nozzles and RHR pipe transition.
In addition, NPPD will review desian basis ASME Class I component fatigue evaluations to determine whether the CNS locations that have been evaluated for the effects of the reactor coolant environment on fatigue include the limiting component within the reactor coolant pressure boundary. If a more limiting component is identified, NPPD will determine the effects of the reactor coolant environment on its fatigue usage in accordance with the following.
(1) Update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case). NPPD will use NUREG/CR-6909 when determining the effects of the reactor coolant environment on the fatigue life of Alloy 600 or other nickel alloy components.
(2) Repair or replace the affected locations before exceeding a CUF of 1.0.
Basis for change: Change requested in a conference call with the NRC Staff on November 10, 2010.
2 The changes shown are made against Revision 2 of this commitment submitted in NLS20 10044 on April 28, 2010 (ADAMS Accession Number ML101250530).
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4
Correspondence Number: NLS2010100 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 Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE Consideration of the effect of the reactor water environment will be accomplished through implementation of one or more of the following options for the reactor vessel shell and lower head, feedwater nozzles, core spray nozzles and RHR pipe transition. In addition, NPPD will review design basis ASME Class 1 component fatigue evaluations to determine whether the CNS locations that have been evaluated for the effects of the reactor coolant environment on fatigue include the limiting component within the reactor coolant pressure boundary. If a more limiting component is identified, NPPD will determine the effects of the reactor coolant environment on its fatigue usage in accordance with the following.
(1) Update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined using an NRC-approved version of the ASME code or NRC-approved alternative (e.g.,
NRC-approved code case). NPPD will use NUREG/CR-6909 when determining the effects of the reactor coolant environment on the fatigue life of Alloy 600 or other nickel alloy components.
(2) Repair or replace the affected locations before exceeding a CUF of 1.0.
The CNS Fatigue Monitoring Program will be enhanced to require the recording of each transient associated with the actuation of a safety/relief valve (SRV).
NLS2008071-08 (Revision 3)
January 18, 2012 I PROCEDURE 0.42 REVISION 27 PAGE 18 OF 26