View source for NLS2016075, Response to Nuclear Regulatory Commission RAI Regarding License Amendment Request to Adopt TSTF-425, Rev 3

{{Adams
| number = ML16355A010
| issue date = 12/07/2016
| title = Response to Nuclear Regulatory Commission RAI Regarding License Amendment Request to Adopt TSTF-425, Rev 3
| author name = Higginbotham K
| 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 = NLS2016075
| document type = Response to Request for Additional Information (RAI)
| page count = 4
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:H Nebraska Public Power District Always there when you need us NLS2016075 December 7, 2016 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001

==Subject:==
 . Response to Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Revision 3 Cooper Nuclear Station, Docket No. 50-298, DPR-46

==References:==
: 1.      Email from Thomas Wengert, U.S. Nuclear Regulatory Commission, to Jim Shaw, Nebraska Public Power District, dated November 29, 2016, "Cooper Nuclear Station - Formal Request for Additional Information Concerning License Amendment Request to Adopt TSTF-425, Revision 3" (CAC MF7498)
: 2. Letter from Oscar A. Limpias, Nebraska Public Power District, to the U.S.
Nuclear Regulatory Commission, dated March 22, 2016, "Application for Technical Specifications Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program"

==Dear Sir or Madam:==

The purpose of this letter is for the Nebraska Public Power District to respond to the Nuclear Regulatory Commission's Request for Additional Information (RAJ) (Reference 1) related to the Cooper Nuclear Station License "Application for Technical Specifications Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program" (Reference 2).
The response to the RAJ is provided in the attachment to this letter.
This letter does not contain any new regulatory commitments.
If you have any questions concerning this matter, please contact Jim Shaw, Licensing Manager, at (402) 825-2788.
COOPER NUCLEAR STATION P.O. Box 98 /Brownville, NE 68321-0098 Telephone: (402) 825-3811 /Fax: (402) 825-5211 www.nppd.com

NLS2016075 Page 2 of2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on:       I *z_.(7 1/~t; (Date)
Sincerely,
    /t_
Ken Higginbotham General Manager o
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==Attachment:==
Response to Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Revision 3 cc: Regional Administrator w/ attachment USNRC - Region IV Cooper Project Manager w/ attachment USNRC - NRR Plant Licensing Branch IV-2 Senior Resident Inspection w/ attachment USNRC-CNS NPG Distribution w/o attachment CNS Records w/ attachment

NLS2016075 Attachment Page 1 of2 Attachment
* Response to Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Revision 3 Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 The Nuclear Regulatory Commission Request for Additional Information (RAI) regarding the License Amendment Request to adopt Technical Specifications Task Force (TSTF) Traveler, TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force Initiative 5b" is shown in italics. The Nebraska Public Power District (NPPD) response to the request is shown in normal font.
Electrical Engineering Branch RAI-1 10 CFR 50.36(c)(3), "Surveillance Requirements," states that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The CNS submittal dated March22, 2016, Attachment 3, page 3.8-18, Surveillance Requirement (SR) 3.8.4. 7, shows a deletion (stricken language below) in Note 1 that pertains to the testing of the safety-related batteries:
The modified performance discharge test in SR 3.8.4.B8 may be performed in lieu of the service test in SR 3.8.4. 7 eneeper 60 menths.
The licensee provided the following justification for the change in Page 3, Subsection 2. 2.3, of :
CNS TS SR 3.8.4. 7, Note 1, is being revised to delete the.frequency of "once per 60 months." This change is consistent with the latest revision ofNUREG-1433. CNS TS SR 3.8.4. 7 reflects the surveillance requirement of[Standard Technical Specification] STS SR 3.8.4.3 which contains a similar Note. However, the STS 3.8.4.3Note1 does not contain the reference to the Frequency of the modifiedperformance discharge test. This change allows the modified performance discharge test in CNS TS SR 3.8.4.8 to be performed in lieu of the service test in CNS TS SR 3.8.4. 7 at the Frequency established in the [Surveillance Frequency Control Program] SFCP.
The justification provided by the licensee is administrative in nature. The language proposed to be deleted is a technical change that is part of the condition allowing the licensee to perform a modified performance test in lieu ofa service test. Please provide the technical basis for the change, including confirmation that the modified performance discharge test completely encompasses the load profile of the battery service test, and that the intent of the service test is to verifY the battery capacity to supply the design basis load profile.

NLS2016075 Attachment Page 2 of2 NPPD Response Consistent with Institute of Electrical and Electronics Engineers (IEEE) 450-1995, (Reference 7 in Technical Specifications Bases 3.8.4) a modified performance discharge test encompasses the duty cycle of the service test. Surveillance Requirements 3.8.4.7 and 3.8.4.8 specify that the service test and modified performance test are encompassed by the duty cycle requirements specified in design calculations. As stated in IEEE 450-1995 Section 5.4, "A modified performance test can be used in lieu of a service test at any time."
The modified performance discharge test has an initial load for one minute that exceeds the maximum load in design calculations followed by a load determined from the battery design that also exceeds the design basis load profile. Therefore, either a service test or modified performance discharge test verify battery capacity to support the design basis load profile.}}