ML20195E895

Application for Amend to License DPR-46,correcting Method by Which SGTS Heaters Are to Be Tested

ML20195E895
Person / Time
Site:	Cooper
Issue date:	06/08/1999
From:	Swailes J NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20195E902	List: ML20195E895 ML20195E910
References
NLS990027, NUDOCS 9906140131
Download: ML20195E895 (5)

Text

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l~ H Nebraska Public Power District

. Nebraska's Energy Leader NLS990027 I l

June 8,1999 l U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

Subject:

Proposed Change to CNS Technical Specifications i Ventilation Filter Testing Program Reference 1 Cooper Nuclear Station, NRC Docket 50-298, DPR-46

Reference:

1) Improved Technical Specification Section 5.5.7e In accordance with the provisions of 10 CFR 50.4 and 50.90 the Nebraska Public Power District (the District) hereby submits a request for an amendment to License DPR-46 to change the Cooper Nuclear Station (CNS) Technical Specifications. The proposed change corrects the described method by which the Standby Gas Treatment system heaters are to be tested. This change is necessary because the reference provided in Reference 1)is in error.

Attachment I contains the bases for the change, the no significant hazard consideration determination, and the CNS Technical Specification page revised by this change. This l proposed change has been reviewed by the necessary safety review committees and incorporates all amendments to the CNS Facility Operating License through Amendment 178 issued July 31,1998.

By copy of this letter and its attachment the appropriate State of Nebraska official is being notified in accordance with 10 CFR 50.91 (b)(1). Copies to the NRC Region IV office and the CNS Resident inspector are also being provided in accordance with 10 CFR 50.4 (b)(2). f Should you have any questions or require any additional information regarding this submittal, please contact Guy Cesare at (402) 825-5433.

Sincerely, A

J hn II. Sm ' es Vic resi nt of c ar E iergy

! Cooper Nudear Station

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• I Po. Box 98/ Brownville, NE 683214098 n

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r,  :- .-4, NLS990027 June 8,1999 Page 2 of 3

/ gal:nr Attachment cc: Regional Administrator w/ attachment USNRC - Region IV Senior Project Manager w/ attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ attachment USNRC Environmental Health Division - Program Manager w/ attachment Nebraska Department of Health NPG Distribution w/o attachment i

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NLS990027 June 8,1999

Page 3 of 3 STATE'OF NEBRASKA )~

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i NEMAHA COUNTY )

John H. Swailes, 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 State of Nebraska; that he is duly authorized to submit this correspondence on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.

.A _Ws AJM -

7 ' Jo 1. S'wailes

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Subscribed i ypfesence and sworn to before me this J day of (La .

1999. d a ha.G><.Ln

. . . . NOTA

. . .R.Y P.UB.LIC. . . ., .. .

l Wilma M. Werner l l h General Notary  ;

< db State of Nebraska >

l My Commission Expires Oct. 26,2002 j I

4' Attachm:nt 1 To NLS990027 Page 1 of 2 COOPER NUCLEAR STATION IMPROVED TECHNICAL SPECIFICATIONS I VENTILATION FILTER TESTING PROGRAM Revised Pane 5.0-13 1.0 Introduction This proposed change to Cooper Nuclear Station (CNS) Technical Specifications provides clarification of the method to be used in demonstrating that the heaters for the Standby Gas Treatment (SGT) system can dissipate the required power. - The present reference to ASME N510-1980, Section 14.5.1 is inappropriate; no such section exists. The relevant section of ASME N510 is entitled " Power-On Electrical Tests;" this section is 14.2.3 in the 1980 standard and 14.5.1 in the 1989 standard. The proposed change specifies the method to be used in demonstrating operability of the SGT heaters.  !

2.0 Discussion Amendment 178 to the CNS Operating License implemented Improved Technical Specifications (ITS). Prior to ITS implementation on August 15, 1998, the requirement was to demonstrate that inlet SGT heater input was capable of reducing relative humidity from 100% to 70% once per operating cycle. The system design basis requires that the heaters be capable of reducing influent relative humidity to 70% under accident conditions. The minimum heat dissipation needed to achieve this humidity reduction is 7.8 kW, Pre-existing requirements regarding ventilation filter testing were a requirement in CNS Custom Technical Specifications and were incorporated into Technical Specification 5.5.7 as part ofITS conversion. During the conversion, reference to ASME N510 was added to clarify testing requirements. However, paragraph 14.5.1 was incorrectly referenced, rather than paragraph 14.2.3. The proposed change removes the reference to ASME

- N510, while prescribing the testing method that will adequately determine heater operability.

3.0 . Descriotion of Channes

(

l The following is proposed to rectify an incorrect reference and specifies the test method used to demonstrate operability.

Section 5.5.7e (cane 5.0-13)

Replace "when tested in accordance with ASME N510-1980, Section 14.5.1" with "by measuring the voltage and current of each phase of the heater circuit at rated system flow."

Attachment 1 To NLS990027 Page 2 of 2 l 4.0 ,

Sinnificant Hazard Determination 10 CFR 50.91 (a) (1) requires that licensee requests for operating license amendments be accompanied by an evaluation of significant hazard posed by issuance of an amendment. This evaluation is performed with respect to the criteria given in 10 CFR 50.92 (c).

4.1 The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated. The correction of an error and clarification of a testing method does not alter any of the precursors assumed in the CNS accident analysis. The proposed wording for testing SGT heaters is in accordance with ASME N510-1989, Section 14.5.1," Testing ofNuclear Air Treatment Systems." Since the proposed change does not affect this portion of plant design and operation, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

4.2 The proposed change will not create the possibility of a new or different kind of accident than evaluated in the Updated Safety Analysis Report (USAR).

The proposed change does not result in any physical change to CNS structures, systems, or components, nor does it change the fit, form, or function of any equipment or components taken credit for in the accident analyses described in the USAR. Therefore, correction of a test reference and specific description of l the testing method for SGT heaters does not create the possibility of a new or different kind of accident.

4.3 The proposed change will not create a significant reduction in the margin of safety. The proposed change does not alter the design or administrative j controls necessary to ensure the required performance of the physical barriers l- during anticipated operational occurrences and postulated accidents. This conclusion is based on the fact that the proposed change corrects an erroneous l

reference, conforms to industry standards, and is consistent with past and current operating practice at CNS; therefore, the proposed change does not create a significant reduction in the margin of safety.

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5.0 Conclusion The District has evaluated the proposed change described above against the criteria of 10 CFR 50.92 in accordance with the requirements of 10 CFR 50.91 (a) (1). . This evaluation has determined that the proposed change to the Tecimical Specifications will not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the l

l possibility for a new or different kind of accident from any accident previous evaluated, or (3) create a significant reduction in the margin of safety.

Therefore, the District requests Nuclear Regulatory Commission approval of this proposed change.