Letter Sequence RAI |
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TAC:ME7169, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed) |
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MONTHYEARNLS2011071, License Amendment Request for Implementing a 24-Month Fuel Cycle and Adoption of TSTF-493, Revision 4, Option a2011-09-16016 September 2011 License Amendment Request for Implementing a 24-Month Fuel Cycle and Adoption of TSTF-493, Revision 4, Option a Project stage: Request ML1128600732011-10-13013 October 2011 Notice of Meeting with Nebraska Public Power District to Discuss Amendment Request to Implement a 24-Month Fuel Cycle and Adopt Technical Specification Task Force (TSTF)-493, Revision 4, for Cooper Nuclear Station Project stage: Meeting ML1129715762011-10-24024 October 2011 Licensee Slides from 10/24/11 Meeting with Nebraska Public Power District to Discuss Cooper Nuclear Station Project stage: Meeting ML1130100232011-10-27027 October 2011 Acceptance Review Email, License Amendment Request to Revise Technical Specifications to Support Operation with 24-Month Fuel Cycle and to Incorporate TSTF-493, Revision 4, Consistent with Option a Project stage: Acceptance Review ML1132200762011-12-0505 December 2011 Summary of Meeting with Nebraska Public Power District to Discuss Amendment Request to Implement a 24-Month Fuel Cycle and Adopt Technical Specification Task Force (TSTF)-493, Revision 4 for Cooper Nuclear Station Project stage: Meeting ML1206203962012-03-0202 March 2012 Request for Additional Information, License Amendment Request, Revise Technical Specifications to Implement a 24-Month Fuel Cycle and Adopt Technical Specification Task Force (TSTF)-493, Revision 4, Option a Project stage: RAI ML1206203922012-03-0202 March 2012 Email, Request for Additional Information, License Amendment Request, Revise Technical Specifications to Implement a 24-Month Fuel Cycle and Adopt Technical Specification Task Force (TSTF)-493, Revision 4, Option a Project stage: RAI ML1208600542012-04-0303 April 2012 Request for Additional Information, License Amendment Request, Revise Technical Specifications to Implement a 24-Month Fuel Cycle and Adopt Technical Specification Task Force (TSTF)-493, Revision 4, Option a Project stage: RAI ML12129A3182012-05-0202 May 2012 Response to Request for Additional Information Regarding License Amendment Request for Implementing a 24-Month Fuel Cycle and Adoption of TSTF-493, Revision 4, Option a Project stage: Response to RAI NLS2012039, Supplement to License Amendment Request for Implementing a 24-Month Fuel Cycle and Adoption of TSTF-493, Revision 4, Option a2012-05-24024 May 2012 Supplement to License Amendment Request for Implementing a 24-Month Fuel Cycle and Adoption of TSTF-493, Revision 4, Option a Project stage: Supplement ML12251A0582012-09-0606 September 2012 Request for Additional Information, License Amendment Request, Round 2, Revise Technical Specifications to Implement a 24-Month Fuel Cycle and Adopt TSTF-493, Revision 4, Option a Project stage: RAI NLS2012100, Response to Request for Additional Information Regarding License Amendment Request for Implementing a 24-Month Fuel Cycle and Adoption of TSTF-493, Revision 4, Option a2012-09-17017 September 2012 Response to Request for Additional Information Regarding License Amendment Request for Implementing a 24-Month Fuel Cycle and Adoption of TSTF-493, Revision 4, Option a Project stage: Response to RAI ML12251A0982012-09-28028 September 2012 Issuance of Amendment No. 242, Revise Technical Specifications to Implement a 24-Month Fuel Cycle and Adopt Technical Specification Task Force (TSTF)-493, Revision 4, Option a Project stage: Approval ML12319A0552012-11-21021 November 2012 Correction to Amendment No. 242 Technical Specification (TS) and Safety Evaluation, Revise TSs to Implement a 24-Month Fuel Cycle and Adopt Technical Specification Task Force (TSTF)-493, Revision 4, Option a Project stage: Approval 2012-03-02
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ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST FOR IMPLEMENTING A 24-MONTH FUEL CYCLE AND ADOPTION OF TSTF-493, REVISION 4, OPTION A NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 FACILITY OPERATING LICENSE NO. DPR-46 By letter dated September 16, 2011 (Agencywide Documents Access and Mangement System Accession No. ML11264A165, Nebraska Public Power District (NPPD, the licensee) submitted a license amendment request (LAR) to revise the technical specifications (TS) for Cooper Nuclear Station (Cooper). The proposed LAR would implement 24 month fuel cycle and adopt TSTF-493, Revision 4, Option A. Specifically, the change addresses certain TS Surveillance Requirement frequencies that are specified as 18 months by revising them to 24 months in accordance with the guidance provided in NRC Generic Letter (GL) 91-04.
- 1. TS SR 3.8.4.8 provides a surveillance requirement of 18 months instead of 12 months for completing the performance discharge tests. It is the NRC staffs position that SR 3.8.4.8 should be consistent with industry standard IEEE 450-1995, Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications, Section 5.2.(c) which recommends Annual performance tests of battery capacity should be made on any battery that shows signs of degradation or has reached 85% of the service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% from its capacity on the previous performance test, or is below 90% of the manufacturers rating.
Please provide the technical basis that justifies why an 18 month surveillance requirement is acceptable as opposed to at least once per 12 months.
- 2. Sections 3.1.3 and 3.1.4 of Attachment 1 to the LAR describe emergency core cooling system and Low-Low Set instrumentation whose current setpoint calculations do not bound the projected 30 month drift values and require revised allowable values.
Calculations were not provided for these new allowable values.
Please submit one of the revised setpoint calculations for review. In addition, please submit the corresponding drift analysis with sufficient supporting documentation as to confirm adherence to the Instrument Drift Analysis Design Guide in Enclosure 1 of the LAR.
- 3. Please provide additional detail on the surveillance test history for the emergency core cooling system (ECCS). Attachment 5 page 16 of the LAR provides details for five ECCS Technical Specification failures. Please provide the total number of surveillance tests considered or the percentage of the surveillance tests that those 5 failures represent.