ML20216H048

Application for Amend to License DPR-46,exempting Neutron Detectors from Channel Calibr Requirements Described in TS 4.2.C.Application Supersedes 980402 Request.Revised OL Pages,Encl

ML20216H048
Person / Time
Site:	Cooper
Issue date:	04/15/1998
From:	Swailes J NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20216H053	List: ML20216H048 ML20216H057
References
NLS980068, NUDOCS 9804210027
Download: ML20216H048 (6)

Text

P.O. 00X B ILL EB 68321 l Nebraska Public Power District *!?x$fatt""

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NLS980068 April 15,1998 I-

! U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

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Subject:

Proposed Change to CNS Technical Specifications l Neutron Monitoring (NM) Neutron Detectors Cooper Nuclear Station, NRC Docket 50-298, DPR-46 l

Reference:

1) Letter from G. R. Horn to USNRC, dated April 2,1998," Proposed Change to i

CNS Technical Specifications, Neutron Monitoring (NM) Neutron Detectors",

NLS980036.

l 2) Letter from G. R. Horn to USNRC, dated March 27,1997," Proposed Change to CNS Technical Specifications, Conversion to Improved Standard Technical Specifications" l

l 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 i Cooper Nuclear Station (CNS) Technical Specifications. This letter supersedes the Technical j[

Specification amendment requested in Reference 1. The proposed change exempts the neutron detectors from the channel calibration requirement described in Technical Specification Table

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l l 4.2.C. This proposed change is also consistent with the Improved Technical Specification (ITS)

L submittal (Reference 2).

Attachment I contains the bases for the change, the no significant hazard consideration determination, and the CNS Technical Specification pages revised by this change. This proposed change has been reviewed by the necessary safety review committees and incorporates all amendments to the CNS Facility Operating License through Amendment 176 issued May 9, 1997.

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).

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. 'NLS980068 '

Page 2 of 3 l

Should you have any questions or require any additional information regarding this submittal, j' please contact Brad Houston at (402) 825-5819.

Sincerely, l

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! J. II. Swailes Vice President of Nuclear Energy l

/dm j Attachment I cc: Regional Administrator w/ attachment USNRC - Region IV Senior Project Manager w/ attachment USNRC - NRR Project Directorate IV-1 l

l Senior Resident Inspector w/ attachment USNRC Environmental Health Division - Program Manager w/ attachment

! Nebraska Departmer' afIlealth ,

l NPG Distribution w/o attachment 1

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, . 'NLS980068 Page 3 of 3 STATE OF NEBRASKA )

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NEMAHA COUNTY )

M. F. Peckham, being first duly swom, 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 conespondence on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.

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'M. F. Peckham Subscribed in my presence and sworn to before me this h ay ofJ [b,1998.

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GENE 8ENOTEstate of Nebtash T/ b~

o i f ,/ , 3 LUCI V. A. PATZEL W Comm.Exn 4 3.2000

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' Attachment I to NLS980068 j Page 1 of 3 1

COOPER NUCI EAR STATION l

TECIINICAL SPECIFICATIONS NEUTRON MONITORING SYSTEM NEUTRON DETECTORS l

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Revised Pages 2

77 81 1.0 Introduction This proposed change to Cooper Nuclear Station (CNS) Technical Specifications exempts the neutron detectors from the requirements of channel calibrations.

Channel calibration is a complete check of the instrument loop and the sensor. l The test verifies that the channel responds to the measured parameter within the necessary range and accuracy. This change is required since CNS is unable to fulfill the verbatim requirements of the above Technical Specification j

! requirements. Because of the location of the neutron detectors and the manner in which they perfbrm their function, it is impossible to calibrate them during power -

operation and very difficult even during shutdown conditions.

2.0 Discussion ,

The proposed exclusion of the neutron detectors from the channel calibration is I requested based on the fact that they are designed to have relatively constant sensitivity over the expected range and with an accuracy specified for a fixed l useful life. Any changes in neutron detector sensitivity are compensated for by l performing Average Power Range Monitors (APRM) heat balances and the Local Power Range Monitor (LPRM) calibration against the Traversing Incore Probes (TIP). This proposed exclusion is in agreement with the Standard Technical l Specifications and, in particular, the CNS Improved Technical Specifications (ITS) already submitted to the NRC.

3.0 Descrintion of Changes f

The following are the proposed changes that are required to bring CNS into verbatim compliance with the Technical Specifications.

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. ' Attachment I to NLS980068 Page 2 of 3 Definitions Section (page 2)

Under subsection 1.2, Instrument Calibration, aller the second sentence the following sentence was added " An exception is that the neutron detectors need l not be subject to the requirements of channel calibrations".

l l l Table 4.2.C (page 77) l A note (15) has been added, where appropriate, to the calibration frequency column.

1 Notes for Tables 4.2.A through 4.2.F '

Note 15 has been added which exempts the neutron detectors from the requirements of channel calibrations.

2.0 Significant 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 the issuance of an amendment. This evaluation is performed with respect to the criteria given in 10 CFR 50.92 (c).

2.1 The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated. The function of the Neutron Monitoring System is to detect conditions in the core that threaten the overall integrity of the fuel barrier due to excessive power generation and provide signals to the reactor protection system, so that the release of radioactive material from the fuel barrier is limited. Exempting the neutron detectors from the requirements of a channel calibration does not alter any of the precursors of the accidents analyzed in the CNS Updated Safety Analysis Report (USAR). The neutron detectors are fission chambers that are designed to have relatively constant sensitivity over the expected range and with an accuracy specified for a fixed useful life. In addition, any changes in neutron detector sensitivity are compensated for by performing APRM heat balance and the LPRM calibration against the TIPS. Thus, even without channel calibration, the neutron detectors will perform their safety function with no significant increase in the consequences of an accident. Therefore, exempting the neutron detectors from channel calibration in the CNS Technical Specifications does not involve a significant increase in the probability or consequences of an accident previously evaluated.

l 2.2 The proposed change will not create the possibility of a new or different kind of accident than evaluated in the USAR. The proposed change does not result in any physical change to CNS structures, systems, or components, nor does it change

Attachment 1 to NLS980068 Page 3 of 3 the fit, form, or function of any equipment or components taken credit for in the accident analyses described in the USAR. Therefore, the exempting the neutron detectors from a channel calibration in the Technical Specifications does not create the possibility of a new or different kind of accident. -

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1 2.3 The proposed exemption of the neutron detectors from the requirements of I channel calibrations in the CNS Technical Specifications will not reduce the margin of safety. This conclusion is based on the ability of the neutron detectors to perform their safety function as required by the CNS accident analysis.

3.0 Conclusion l f

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The District has evaluated the proposed changes 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  !

Technical Specifications will not (1) involve a significant increase in the l probability or consequences of an accident previously evaluated, (2) create the possibility for a new or different kind of accident from any accident previously evaluated, or (3) create a significant reduction in the margin of safety. Therefore, the District requests NRC approval of this proposed change.

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