ML13008A181
| ML13008A181 | |
| Person / Time | |
|---|---|
| Site: |  |
| Issue date: | 01/03/2013 |
| From: | O'Grady B J Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2013001, TAC ME7324 | |
| Download: ML13008A181 (5) | |
Text
HNebraska Public Power DistrictAlways theTe when you need us50.90NLS2013001January 3, 2013U.S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, D.C. 20555-0001Subject:Response to Request #3 for Additional Information Re: License AmendmentRequest 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-46References: 1.E-mail from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, toEdward L. McCutchen, Jr., Nebraska Public Power District, datedDecember 3, 2012 (Accession No. ML12338A264), "Request forAdditional 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, "Supplementto 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, "LicenseAmendment Request to Revise Technical SpecificationPressure/Temperature Limit Curves and Surveillance Requirements"(NLS2011015)4. Letter from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, toBrian 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 toRequest for Additional Information re: License Amendment Request toRevise Technical Specification 3.4.9, 'RCS Pressure and Temperature(P/T) Limits' (TAC NO. ME7324)"COOPER NUCLEAR STATIONP.O. Box 98 / Brownville, NE 68321-0098Telephone: (402) 825-3811 / Fax: (402) 825-5211www.nppd.com NLS2013001Page 2 of 36. Letter from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, toBrian 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 toRequest #2 for Additional Information Re: License Amendment Request toRevise 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 arequest 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 SpecificationPressure/Temperature (P/T) Limit Curves and Surveillance Requirements to operate beyond 28Effective Full Power Years (EFPY). NPPD had previously responded to two sets of RAIs fromthe NRC (References 4, 5, 6 and 7), and our responses to the specific RAI questions in ReferenceI are provided in the Attachment to this letter.Based on telephone discussions between NRC and NPPD staffs concerning the RAIs inReference 1, NPPD hereby withdraws the Supplement submitted in Reference 2 and requests theNRC approve our original LAR submitted by Reference 3. This letter also rescinds theregulatory commitments previously made in Reference 7 to resubmit the P/T curves after NRCapproval of the generic methodology for nozzles, since NRC has approved the methodology andReference 3 already includes the instrument nozzles. The other commitment made in Reference7 to resubmit the P/T curves without the instrument nozzles was met in Reference 2, which isnow 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 thebasis of the no significant hazards consideration evaluation provided with Reference 3. Thisletter 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.Executed on Zfch "a."t 61((date) (3 NLS2013001Page 3 of 3SincrelY,/Brian J. 0' radyVice President -Nuclear dChief Nuclear Officer/emAttachment:Response to Nuclear Regulatory Commission Request for Additional InformationRe: Technical Specification 3.4.9, "RCS Pressure and Temperature (P/T) Limits"(TAC NO. ME7324)cc: Regional Administrator w/ attachmentUSNRC -Region IVCooper Project Manager w/ attachmentUSNRC -NRR Project Directorate IV-1Senior Resident Inspector w/ attachmentUSNRC -CNSNebraska Health and Human Services w/ attachmentDepartment of Regulation and LicensureNPG Distribution w/o attachmentCNS Records w/ attachment NLS2013001AttachmentPage 1 of 2AttachmentResponse to Nuclear Regulatory Commission (NRC) Request for Additional InformationRe: Technical Specification 3.4.9, "RCS Pressure and Temperature (P/T) Limits"(TAC NO. ME7324)Cooper Nuclear Station, Docket No. 50-298, DPR-46NRC Question #1By letter dated September 28, 2012, the licensee revised their License Amendment Request(LAR) to include new proposed 32 EFPY Technical Specification (TS) P-T limit curves. The newproposed P-T limit curves differ from the ones submitted in the original LAR, dated September22, 2011, in that they remove consideration of the reactor pressure vessel (RPV) instrumentnozzles, Whereas the 32 EFPY curves submitted in the original LAR showed the instrumentnozzles to define part of the bounding curves, these revised curves were developed withoutconsideration of the instrument nozzles. Therefore the staff cannot approve the new proposedcurves if these curves are not bounding for the RPV instrument nozzles.Therefore, the staff requests that the licensee either (1) provide technical justification for whythe new proposed P-T limit curves are bounding for the instrument nozzles, or (2) revise theproposed P-T limit curves such that they are consistent with those proposed in the original LARsubmittal.Response #1A clarifying telephone call between NRC and Nebraska Public Power District (NPPD)staffs was conducted on November 14, 2012 concerning the draft requests for additionalinformation (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 beacceptable by the NRC. This removed the NRC's objection to the original LAR whichwas the reason NPPD had submitted the Supplement. Based on this discussion, NPPDhereby withdraws the Supplement submitted on September 28, 2012 (Reference 2) andrequests the NRC to approve the original LAR submitted on September 22, 2011(Reference 3). In light of this development, NPPD also rescinds the regulatorycommitments previously made to resubmit the curves without the analysis of theinstrument nozzles as a supplement to this LAR, and then later, after NRC approval ofthe generic methodology for nozzles, submit another LAR to revise the curvesconsidering the nozzles.NRC Question #2Ferritic reactor coolant pressure boundary (RCPB) components that are not part of the reactorpressure vessel (RPV) may have initial nil-ductility reference temperature (RT NDT) values thatmay define a more restrictive lowest service temperature (LST) in the P -T limits than those for NLS2013001AttachmentPage 2 of 2the RPV components. For any ferritic piping pumps and valves greater than 2.5 inches inthickness, the staff requests that the licensee address how the proposed 32 EFPY P-T limitmeet the Lowest Service Temperature Requirements of the ASME Code, Section iIl, NB-2332(b)Response #2The Cooper Nuclear Station (CNS) Class 1 ferritic piping systems were designed toANSI 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 2.5inches. However brittle failure was considered in the design of the CNS piping system.