View source for NLS2013001, Response to Request 3 for Additional Information License Amendment Request to Revise Technical Specification 3.4.9, RCS Pressure and Temperature (P/T) Limits

{{Adams
| number = ML13008A181
| issue date = 01/03/2013
| title = Response to Request #3 for Additional Information License Amendment Request to Revise Technical Specification 3.4.9, RCS Pressure and Temperature (P/T) Limits
| author name = O'Grady B
| author affiliation = Nebraska Public Power District (NPPD)
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000298
| license number = DPR-046
| contact person = 
| case reference number = NLS2013001, TAC ME7324
| document type = Letter type:NLS
| page count = 5
| project = TAC:ME7324
| stage = Request
}}

=Text=
{{#Wiki_filter:H Nebraska Public Power District Always theTe when you need us 50.90 NLS2013001 January 3, 2013 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

==Subject:==
Response to Request #3 for Additional Information Re: License Amendment Request to Revise Technical Specification 3.4.9, "RCS Pressure and Temperature (P/T) Limits" (TAC NO. ME7324)
Cooper Nuclear Station, Docket No. 50-298, DPR-46

==References:==
: 1. E-mail from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, to Edward L. McCutchen, Jr., Nebraska Public Power District, dated December 3, 2012 (Accession No. ML12338A264), "Request for Additional Information Re: Cooper P-T Curves LAR (ME7324)"
: 2. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated September 28, 2012, "Supplement to License Amendment Request to Revise Technical Specification 3.4.9,
                      'RCS Pressure and Temperature (P/T) Limits' (TAC NO. ME7324)"
: 3. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated September 22, 2011, "License Amendment Request to Revise Technical Specification Pressure/Temperature Limit Curves and Surveillance Requirements" (NLS2011015)
: 4. Letter from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, to Brian J. O'Grady, Nebraska Public Power District, dated February 29, 2012, "Cooper Nuclear Station - Request for Additional Information Re:
License Amendment Request to Revise Technical Specification 3.4.9,
                      'RCS Pressure and Temperature (P/T) Limits' (TAC No. ME7324)"
: 5. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated March 30, 2012, "Response to Request for Additional Information re: License Amendment Request to Revise Technical Specification 3.4.9, 'RCS Pressure and Temperature (P/T) Limits' (TAC NO. ME7324)"
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2013001 Page 2 of 3
: 6. Letter from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, to Brian J. O'Grady, Nebraska Public Power District, dated August 10, 2012, "Cooper Nuclear Station - Request for Additional Information Re:
License Amendment Request to Revise Technical Specification 3.4.9,
                        'RCS Pressure and Temperature (P/T) Limits' (TAC No. ME7324)"
: 7. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated September 10, 2012, "Response to Request #2 for Additional Information Re: License Amendment Request to Revise Technical Specification 3.4.9, 'RCS Pressure and Temperature (P/T)
Limits' (TAC NO. ME7324)"

==Dear Sir or Madam:==

The purpose of this letter is for Nebraska Public Power District (NPPD) to submit a response to a request for additional information (RAI) from the Nuclear Regulatory Commission (NRC)
(Reference 1). The RAI requested information in support of NRC's review of the Supplement (Reference 2) to the license amendment request (LAR) for the Cooper Nuclear Station (CNS) facility operating license (Reference 3). The LAR requested revision of Technical Specification Pressure/Temperature (P/T) Limit Curves and Surveillance Requirements to operate beyond 28 Effective Full Power Years (EFPY). NPPD had previously responded to two sets of RAIs from the NRC (References 4, 5, 6 and 7), and our responses to the specific RAI questions in Reference I are provided in the Attachment to this letter.
Based on telephone discussions between NRC and NPPD staffs concerning the RAIs in Reference 1, NPPD hereby withdraws the Supplement submitted in Reference 2 and requests the NRC approve our original LAR submitted by Reference 3. This letter also rescinds the regulatory commitments previously made in Reference 7 to resubmit the P/T curves after NRC approval of the generic methodology for nozzles, since NRC has approved the methodology and Reference 3 already includes the instrument nozzles. The other commitment made in Reference 7 to resubmit the P/T curves without the instrument nozzles was met in Reference 2, which is now being withdrawn. Thus, NPPD now rescinds that commitment as well.
The information submitted by this response to the RAI does not change the conclusions or the basis of the no significant hazards consideration evaluation provided with Reference 3. This letter also does not contain any regulatory commitments.
If you have any questions concerning this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.
I declare under penalty of perjury that the foregoing is true and correct.
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NLS2013001 Page 3 of 3 SincrelY,/
Brian J. 0' rady Vice President - Nuclear    d Chief Nuclear Officer
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==Attachment:==
Response to Nuclear Regulatory Commission Request for Additional Information Re: Technical Specification 3.4.9, "RCS Pressure and Temperature (P/T) Limits" (TAC NO. ME7324) 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/o attachment CNS Records w/ attachment

NLS2013001 Attachment Page 1 of 2 Attachment Response to Nuclear Regulatory Commission (NRC) Request for Additional Information Re: Technical Specification 3.4.9, "RCS Pressure and Temperature (P/T) Limits" (TAC NO. ME7324)
Cooper Nuclear Station, Docket No. 50-298, DPR-46 NRC Question #1 By letter dated September 28, 2012, the licensee revised their License Amendment Request (LAR) to include new proposed32 EFPY Technical Specification (TS) P-T limit curves. The new proposed P-T limit curves differ from the ones submitted in the originalLAR, dated September 22, 2011, in that they remove considerationof the reactorpressure vessel (RPV) instrument nozzles, Whereas the 32 EFPY curves submitted in the originalLAR showed the instrument nozzles to define part of the bounding curves, these revised curves were developed without considerationof the instrument nozzles. Therefore the staff cannot approve the new proposed curves if these curves are not bounding for the RPV instrument nozzles.
Therefore, the staff requests that the licensee either (1) provide technicaljustification for why the new proposedP-T limit curves are bounding for the instrument nozzles, or (2) revise the proposed P-T limit curves such that they are consistent with those proposed in the originalLAR submittal.
Response #1 A clarifying telephone call between NRC and Nebraska Public Power District (NPPD) staffs was conducted on November 14, 2012 concerning the draft requests for additional information (RAIs) which were subsequently sent via docketed e-mail dated December 3, 2012. From that discussion, NPPD understands that the Structural Integrity Associates (SIA) methodology upon which NPPD had based the original submittal was found to be acceptable by the NRC. This removed the NRC's objection to the original LAR which was the reason NPPD had submitted the Supplement. Based on this discussion, NPPD hereby withdraws the Supplement submitted on September 28, 2012 (Reference 2) and requests the NRC to approve the original LAR submitted on September 22, 2011 (Reference 3). In light of this development, NPPD also rescinds the regulatory commitments previously made to resubmit the curves without the analysis of the instrument nozzles as a supplement to this LAR, and then later, after NRC approval of the generic methodology for nozzles, submit another LAR to revise the curves considering the nozzles.
NRC Question #2 Ferriticreactorcoolant pressure boundary (RCPB) components that are not part of the reactor pressure vessel (RPV) may have initialnil-ductilityreference temperature(RT NDT) values that may define a more restrictivelowest service temperature (LST) in the P -T limits than those for

NLS2013001 Attachment Page 2 of 2 the RPV components. For any ferritic piping pumps and valves greaterthan 2.5 inches in thickness, the staff requests that the licensee address how the proposed 32 EFPY P-T limit meet the Lowest Service Temperature Requirements of the ASME Code, Section iIl, NB-2332(b)
Response #2 The Cooper Nuclear Station (CNS) Class 1 ferritic piping systems were designed to ANSI B31.1-1967. At the time of construction ASME Section III did not apply to piping, pumps or valves. Thus NB-2332(b) does not specifically apply to CNS. Furthermore, the nominal wall thicknesses of the Class 1 ferritic piping systems are less than 2.5 inches. However brittle failure was considered in the design of the CNS piping system.}}