NLS2013055, Revision to Commitment Made in Reply to Notice of Violation 2012004-02; EA-12-206

Revision to Commitment Made in Reply to Notice of Violation 2012004-02; EA-12-206

ML13154A373
Person / Time
Site:	Cooper
Issue date:	05/24/2013
From:	Limpias O Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-206, NLS2013055
Download: ML13154A373 (3)

Text

H Nebraska Public Power District Always there when you need us NLS2013055 May 24, 2013 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Revision to Commitment Made in Reply to Notice of Violation 2012004-02; EA-12-206 Cooper Nuclear Station, Docket No. 50-298, DPR-46

Reference:

Letter from Brian J. O'Grady, Nebraska Public Power District, to the U.S.

Nuclear Regulatory Commission, dated December 10, 2012, "Reply to Notice of Violation 2012004-02; EA- 12-206"

Dear Sir or Madam:

The purpose of this letter is to communicate the revision of a commitment made to the Nuclear Regulatory Commission (NRC) in the above reference in support of Cooper Nuclear Station's (CNS) reply to Notice of Violation 2012004-02. In that letter, the Nebraska Public Power District committed to complete a special procedure air start test on Diesel Generator (DG) I to demonstrate DG1 air receiver performance similar to Special Procedure SP 12-003 that was completed for DG2 on November 19, 2012, during RE27 and complete NEDC 11-072 Revision

1. The scheduled commitment completion date is May 31, 2013.

Special Procedure SP12-003, DIESEL GENERATOR AIR RECEIVER CAPACITY TEST, performed on DG2 tested the most restrictive starting air receiver of all four air receivers. The 2B air receiver was selected as the most restrictive based on empirical data from multiple starts on both diesel generators. Based on the capacity margins demonstrated on a single Division 2, DG starting air receiver and the nearly identical starting air piping systems for DGI and DG2, there is no technical basis for starting DG1 five times consecutively to prove Division 1 starting air receiver capacity. The adequacy of the Division 1 starting air receiver capacity can be demonstrated analytically. It is necessary to revise the commitment to eliminate the wear and tear associated with'five unnecessary fast starts of DG 1. There is regulatory precedence for minimizing unnecessary wear and tear on emergency diesel generators.

This commitment has been revised as follows: Utilizing information from Diesel Generator No.

2 Special Procedure SP 12-003, DIESEL GENERATOR AIR RECEIVER CAPACITY TEST, complete revision 1 of NEDC 11-072, DGSA Accumulator Sizing Basis, to demonstrate the Starting Air System for Diesel Generator No. I will support multiple diesel engine starts from a single air receiver.

COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5217 www.nppd.com

NLS2013055 Page 2 of 2 The scheduled completion date of the revised commitment remains the same.

The need for this commitment revision was discussed with the NRC Branch Chief for CNS by Licensing Manager, David Van Der Kamp, on May 8, 2013.

If you have questions concerning this matter, please contact David Van Der Kamp at (402) 825-2904.

Sincerely, I'4ý'e & 0- 4 "'qp f"t-!ý Oscar A. Limpia*/

Vice President -'uch Chief Nuclear Officer

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

LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Nebraska Public Power District in this document. Any other actions discussed in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED COMMITMENT/COMMITMENT NO. ONE-TIME CONTINUING COMPLETION COMPLIANCE DATE ACTION Utilizing information from Diesel X May 31, 2013 Generator No. 2 Special Procedure SP 12-003, DIESEL GENERATOR AIR RECEIVER CAPACITY TEST, NPPD will complete revision 1 of NEDC 11-072, DGSA Accumulator Sizing Basis, to demonstrate the Starting Air System for Diesel Generator No. I will support multiple diesel engine starts from a single receiver.

[NLS2012127-01], Rev. 1 i i i t I. I.

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EN-LI-106 Rev. 9C0, Attachment 9.3