View source for NLS8400137, Application to Amend License DPR-46,consisting of Proposed Change 13,revising Tech Specs to Incorporate Mark I Containment Mods,Per NRC 840120 Request.Class III Amend Fee Encl

{{Adams
| number = ML20084L112
| issue date = 05/07/1984
| title = Application to Amend License DPR-46,consisting of Proposed Change 13,revising Tech Specs to Incorporate Mark I Containment Mods,Per NRC 840120 Request.Class III Amend Fee Encl
| author name = Kuncl L
| author affiliation = NEBRASKA PUBLIC POWER DISTRICT
| addressee name = Vassallo D
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000298
| license number = 
| contact person = 
| document report number = NLS8400137, TAC-07934, TAC-55005, TAC-7934, NUDOCS 8405140342
| package number = ML20084L114
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 5
| project = TAC:07934, TAC:55005, TAC:7934
| stage = Request
}}

=Text=
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GENERAL OFFICE h     Nebraska Public Power District NLS8400137
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May 7,1984 Office of Nuclear Reactor Regulation Operating Reactors Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Domenic B. Vassallo, Chief

==Reference:==
: 1) Letter from D. B. Vassallo to J. M. Pilant dated January 20,1984, " Mark I Containment Long-Term Program"

==Attachment:==
: 1) Evaluation of Technical Specification Changes with Respect to 10CFR50.92

==Dear Mr. Vassallo:==

==Subject:==
Proposed Change No.13 to Technical Specifications Mark I Containment Modifications Cooper Nuclear Station NRC Docket No. 50-298, DPR-46 Reference (1) requested Nebraska Public Power District (NPPD) to submit any changes to the facility's Technical Specifications required as a result of Mark I containment modifications.       In accordance with the applicable provisions specified in 10CFR50, NPPD requests that the Technical Specifications for Cooper Nuclear Station (CNS) be revised to incorporate these changes.
An evaluation of the proposed change with respect to the requirements of 10CFR50.92 and the applicable revised Technical Specification pages are contained in the attachment.
This proposed change incorporates all amendments to the CNS Facility Operating License through Amendment 85 issued March 20,1984.
By copy of this letter and attachment, the appropriate State of Nebraska Official is being notified in accordance with 10CFR50.91(b) .
This change has been reviewed by the necessary Safety Review Committees and payment for a Class III amendment in the amount of $4,000 is submitted.
8405140342 840507 PDR ADOCK 05000298 P                 PDR                             \

INr. . Domenic B. Vc;:sallo P:ga 2 May 7,1984                                                       i Should you have any questions or require additional information, please contact me.                                                ,.
I In addition to three signed originals, 40 copies are also        :
submitted for your use.                                          ;
Sinc cly ,
i L. G. Kuncl                                                      t Assistant General Manager                                        [
LGK/grs:emz8/3 Attachment                                                       ,
l cc:     H. E. Simmons Department of Health State of Nebraska i
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Idr. Dom 2nic B. Vassallo Pege 3 May 7,1984 STATE OF NEBRASKA)
                                      )ss PLATTE COUNTY           )
L. G. Kuncl, being first duly sworn, deposes and says that he       ;
is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the     i State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his         ,
knowledge and belief.
i L. G. Kubcl           %
Subscribed in my presence and sworn to before me this d day of            @ rijf             , 1984.
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Attachmsnt 1     l Revised Technical Specifications for Mark I Containment Modifications Revised Pages:              65       159          176       179                      ;
66       162a         177       180 80       178          181       184 e
167a (deleted)                                           ,
i Reference (1) stated that the NRC staff completed a postimplementation audit                                    !
review of the CNS Plant Unique Analysis Report (PUAR) and concluded that the PUAR verified that the completed containment modifications have restored the                                    ;
original design safety margin to the Mark I containment. The PUAR states in                                     !
Section 2 that drywell-to-wetvell pressure differentials of 1.0 psid and                                        ;
0.0 paid were both used as initial conditions in the containment structural                                     i evaluations and that although the 0.0 psid differential causes higher loads in                                  i some cases, the design margins are still met. An enclosure to Reference (1)                                     (
(Safety Evaluation Report related to Mark I Containment Long-Term Program)                                     .
concluded that the pool dynamic loads utilized by NPPD in the PUAR were                                         l conservative and acceptable.                                                                                    l Based on the above, NPPD requests a revision to the Technical Specifications                                    !
to delete the requirements to establish and maintain a drywell-suppression                                      ,
chamber differential pressure during reactor operation. Following from this,                                    i the limiting condition of operation and surveillanc.e requirements for the                                      i drywell-suppression chamber differential pressure instrumentation have been                                     i deleted from the Technical Specifications. The maximum suppression pool water                                   ,
volume as stated in Technical Specification 3.7.A.1 has also been changed to 91,100 ft.       to be consistent with the value used in the Mark I evaluations and in the updated Safety Analysis Report.                       In addition, the bases for Technical               >
Specifications 3.7.A and 4.7.A have been reformatted to more closely follow the order of items addressed in the Technical Specifications.                                                   ,
t Additionally, the District requests that Section 4.7.A.2.g be deleted from the Technical Specifications to remove the requirement that the containment be                                      ;
continuously monitored to detect gross leakage of nitrogen. This request is                                     i
(
l           based on the following:                                                                             *
: 1. The issue is covered in earlier parts of 4.7. A.2 under integrated and local leak rate testing in accordance with Appendix J of 10CFR50.
t l
: 2. The requirement as written is ambiguous and subject to varying interpretations in that no quantitative criteria are given as what -                                      !
constitutes gross leakage and how long the monitoring system can be taken out of service for maintenance.                                                                            l l.
: 3. The proposed change conforms to NUREG-0123, Revision 3,                                 Standard Tcchnical Specification 4.6 which does not require continuous monitoring                                   !
l-        _       for gross leakage of the primary containment while it is inerted.                                         i i
!           4. . No bases are given for this surveillance requirement.                               It was added to        !
;                 the Technical Specifications when the Atmospheric Co'ntainment Atmosphere                               a !
l                Dilution (ACAD) system was being licensed.                                                                 !
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l Evaluation of this Revision with Respect to 10CFR50.92 The enclosed Technical Specification change is judged to involve no significant hazards based on the following:
: 1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?                                                                                     j Evaluation:
The PUAR - submitted by NPPD analyzed a drywell-wetwell pressure differential of 0 psid for three categories of Loss-of-Coolant Accident                                                                              >
(LOCA) including the Design Base Accident of a double-ended guillotine break of the recirculation pump suction line at the reactor vessel. It                                                                               ,
concluded that n,o significant increase in the consequences of a LOCA occurred if drywell-wetwell differential pressure was changed from                                                                                   ;
1.0 psid to O psid. Because drywell-wetwell differential pressure.and                                                                                i
             .not continuously m'onitoring the primary containment for. gross leakage                                                                              ,
does not affect the probability of a LOCA occurrence, the proposed change does not involve a significant increase in the probability or consequence                                                                             ;
of an accident previously evaluated.                                                                                                                 v
: 2. Does the proposed license amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Evaluation:
* Because the proposed change does not introduce any new mode of operation, the possibility of an accident of a different type than analyzed in the                                                                              l Final Safety Analysis Report would no.t reault from the change; therefore, the proposed license amendment does not create the possibility of a new or different kind of accident from any accident pre-lously evaluated.                                                                                i i
: 3. Does the proposed amendment involve a significant reduction in a margin                                                                               !
of safety?
Evaluation:
The PUAR for the Mark I Containment Report states that all containment components have sufficient design margins for all leads assuming zero pressure differential between the wetwell and drywe?.1, so the proposed                                                                               ;
change to delete the requirement for drywell-wetwell differential                                                                                    i pressure does not involve a significant reduction in a margin of safety.                                                                             ;
The primary containment is continuously supplied with a supply of inerting nitrogen to handle any leakage that might develop.                                                   In addition,                            ;
gross leakage would be more likely to occur during integrated and local                                                                               l leak rate testing when the applied pressure is far in excess of what would be present during normal operating conditions.                                              These leak rate                                     l' tests are performed at specified intervals with stringent acceptance criteria in accordance with Regulations and the Technical Specifications.                                                                              !
The District believes this change to delete continuous primary                                                                                       )'
containment monitoring clarifies the surveillance requirements on primary containment integrity and is in agreement with the NRC's Standard Technical Specifications and does not involve a significant reduction in a margin of safety.
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