Nebraska Public Power District 50.90 Attn: Document ... · May 2, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Subject: Response

Nebraska Public Power DistrictAlways there when you need us 50.90

NLS2012033May 2, 2012

U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D.C. 20555-0001

Subject: Response to Request for Additional Information Regarding License AmendmentRequest for Implementing a 24-Month Fuel Cycle and Adoption of TSTF-493,Revision 4, Option ACooper Nuclear Station, Docket No. 50-298, DPR-46

References: 1. Letter from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, toBrian J. O'Grady, Nebraska Public Power District, dated April 3, 2012,"Request for Additional Information Re: License Amendment Request forImplementing a 24-Month Fuel Cycle and Adoption of TSTF-493, Revision 4,Option A (TAC No. ME7169)"

2. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.Nuclear Regulatory Commission, dated September 16, 2011, "LicenseAmendment Request for Implementing a 24-Month Fuel Cycle and Adoptionof TSTF-493, Revision 4, Option A" (NLS2011071)

3. NEDC-31336P-A, "General Electric Instrument Setpoint Methodology,"September 1996.

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District (NPPD) to respond to theNuclear Regulatory Commission (NRC) Request for Additional Information (RAI) (Reference 1)relating to the Cooper Nuclear Station (CNS) License Amendment Request for implementing a24-month fuel cycle and adoption of Technical Specification Task Force (TSTF) Traveler TSTF-493, Revision 4, Option A (Reference 2). The responses are provided in Attachment 1.

In Request 2 of Reference 1, the NRC requested the submittal of one of the revised AllowableValue setpoint calculations for review. In a telephone call with the NRC Project Manager onMarch 21, 2012, it was communicated that the setpoint calculation was prepared using theproprietary General Electric Setpoint Methodology (Reference 3). Accordingly, it must bewithheld from public disclosure per 10 CFR 2.390. However, since the calculation was notprepared by the owners of the proprietary information, General Electric Hitachi, it was agreedthat the NRC would waive the need for a new affidavit, provided NPPD cited the originalGeneral Electric affidavit. That affidavit is provided in Enclosure 1. Enclosures 2, 3, and 4provide additional information associated with attached RAI response.

COOPER NUCLEAR STATIONP.O. Box 98 / Brownville, NE 68321-0098

Telephone: (402) 825-3811 / Fax: (402) 825-5271wwwnppd .com

NLS2012033Page 2 of 2

A commitment is made in this submittal (see Attachment 2). Should you have any questionsconcerning this matter, please contact Mike Boyce, CNS Strategic Initiatives Project Manager, at(402) 825-5100.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: A 'Yly A .;

(Dafe)

Sincerely,

ttý rBrian J. O'GradyVice President - Nuclearand Chief Nuclear Officer

BJO/wv

Attachments: 1. Response to Request for Additional Information Regarding LicenseAmendment Request for Implementing a 24-Month Fuel Cycle and Adoptionof TSTF-493, Revision 4, Option A

2. List of Regulatory Commitments

Enclosures: 1. Affidavit from General Electric Requesting NEDC-31336 Be Withheld FromPublic Disclosure

2. NEDC 92-050L, Rev. 2, "Calculation of Calibration Values for Low-Low SetPressure Switches" - PROPRIETARY

3. NLS2011071 Replacement Pages4. NEDC 11-109, Rev. 0, "Instrument Drift Analysis for NBI-PS-51 A/B/C/D"

cc: Regional Administrator w/Attachments and EnclosuresUSNRC - Region IV

Cooper Project Manager w/Attachments and EnclosuresUSNRC - NRR Project Directorate IV-1

Senior Resident Inspector w/Attachments and EnclosuresUSNRC - CNS

Nebraska Health and Human Services w/Attachments and EnclosuresDepartment of Regulation and Licensure

NPG Distribution w/o Attachments and Enclosures

CNS Records w/Attachments and Enclosures

NLS2012033Attachment 1Page 1 of 4

Attachment 1

Response to Request for Additional Information RegardingLicense Amendment Request for Implementing a 24-Month Fuel Cycle and

Adoption of TSTF-493, Revision 4, Option A

The Nuclear Regulatory Commission (NRC) Request for Additional Information (RAI)regarding the subject License Amendment Request (LAR) is shown in italics. The NebraskaPublic Power District's (NPPD) response to each request is shown in block font.

NRC Request 1

TS SR 3.8.4.8 provides a surveillance requirement of 18 months instead of 12 months forcompleting the performance discharge tests. It is the NRC staff's position that SR 3.8.4.8should be consistent with industry standard Institute of Electrical and Electronics Engineers,Inc. (IEEE) 450-1995, "Recommended Practice for Maintenance, Testing, and Replacement ofVented Lead-Acid Batteries for Stationary Applications," Section 5.2. (c) which recommends, inpart, that

Annual performance tests of battery capacity should be made on any battery thatshows signs of degradation or has reached 85% of the service life expected forthe application. Degradation is indicated when the battery capacity drops morethan 10%from its capacity on the previous performance test, or is below 90% ofthe manufacturer's rating.

Please provide the technical basis that justifies why an 18-month SR is acceptable as opposed to"at least once per 12 months."

NPPD Response

NPPD will supplement the 24-Month Cycle License Amendment Request to revise theSurveillance Requirement (SR) 3.8.4.8 18-month frequency to 12 months, consistent with IEEE450-1995. The amended pages will be submitted by June 2, 2012, as agreed to in the March 21,2012 conference call.

NRC Request 2

Sections 3.1.3 and 3.1.4 of Attachment 1 to the LAR describe emergency core cooling system(ECCS) and Low-Low Set instrumentation whose current setpoint calculations do not bound theprojected 30-month drift values and require revised allowable values. Calculations were notprovided for these new allowable values.


Please submit one of the revised setpoint calculations for review. In addition, please submit thecorresponding drift analysis with sufficient supporting documentation as to confirm adherence tothe "Instrument Drift Analysis Design Guide" in Enclosure 1 of the LAR.

NPPD Response

NPPD here provides NEDC 92-050L, Rev. 2, "Calculation of Calibration Values for Low-LowSet Pressure Switches" in Enclosure 2. As previously cited, NPPD requests that this calculationbe withheld from public disclosure, in accordance with 10 CFR 2.390. Since application of theproprietary General Electric setpoint methodology involves mostly inputting Cooper NuclearStation-specific values, this essentially renders the whole calculation as proprietary. Thus, itwould not be meaningful to provide a redacted version with most of the calculation blacked out.During the course of generating this response, NPPD noted a typographical error in one of theTechnical Specification Table 3.3.6.3-1 Low-Low Set Instrumentation Allowable Values.Replacement pages to the License Amendment Request are provided in Enclosure 3.

NPPD has provided NEDC 11-109, Rev. 0, "Instrument Drift Analysis for NBI-PS-51A/B/C/D(Barksdale B2T-M12SS)" in Enclosure 4. This calculation is the corresponding drift analysis forthe Low-Low Set Allowable Value changes, which demonstrates adherence to the InstrumentDrift Analysis Design Guide, as provided in Enclosure 1 to Reference 1.

NRC Request 3

Please provide additional detail on the surveillance test history for the ECCS. Attachment 5page 16 of the LAR provides details for five ECCS TSfailures. Please provide the total numberof surveillance tests considered or the percentage of the surveillance tests that those 5failuresrepresent.

NPPD Response

SR 3.5.1.9 is implemented by Procedures 6.1DG.302 and 6.2DG.302, "Undervoltage LogicFunctional, Load Shedding, and Sequential Loading Test (DIV 1/2)." The testing described initems b) and e) on Attachment 5, Page 5 of 16, were performed under Procedure 6.1DG.302 atleast eleven times from 1997 to 2009. The testing described in items a), c), and d) onAttachment 5, Page 5 of 16, were performed under Procedure 6.2DG.302 at least 9 times from1997 to 2009. While this would appear to be a relatively high nominal failure rate, this is notindicative of the actual reliability of the components tested during these surveillances. As notedin the LAR, each of these five failures was unique. Additionally, many of the components testedby 6.1DG.302 and 6.2DG.302 are also tested during the monthly diesel operability tests andquarterly pump surveillance tests. In addition, Procedures 6.1EE.302 and 6.2EE.302, "4160VBus 1F/G Undervoltage Relay and Relay Timer Functional Test (Div 1/2)" tests the undervoltagerelays themselves as well as a significant portion of remaining undervoltage circuit, including theundervoltage auxiliary relays and timers.


The following more detailed disposition is provided for each of the failures provided in LARAttachment 5, Page 16:

a) For the failure involving the Service Water Pump B time-delay relay, the Service WaterPump breaker was aligned with test blocks installed and mode selector in Standby. Thebreaker did not close during performance of Procedure 6.2DG.302, as expected.Investigation of this event, as described in the Apparent Cause Evaluation for this ConditionReport (CR-CNS-2006-09360), found that the relay coil had failed open, which preventedthe relay from changing state. This, in turn, prevented the breaker from closing as required.The relay in question had been put into service in May 2006. In the absence of definitiveevidence to the contrary, the apparent cause of the subject failure was attributed to infantmortality (May to November, 2006). The relay was purchased as a safety-relatedcomponent, stored appropriately, bench-tested, and tested subsequent to being put inservice. There is no evidence of any event that may have electrically or physically stressedthe relay coil. These Agastat relay coils have no apparent adverse trend of failures through-out the industry.

b) For the failure of Diesel Generator (DG)-I during testing, the failure consisted of a loss of125VDC Control Power (Circuit 4) for DG-1 due to an overcurrent condition, caused byfailure of a Transient Voltage Suppression (TVS) diode network, which ultimately resultedin DG-1 trip during a sequential loading test performed under Procedure 6.1DG.302. TheRoot Cause Evaluation for this Condition Report (CR-CNS-2005-01360) identified that themost likely cause of failure was a manufacturing defect of the rectifier diode in the TVScircuit causing it to short. The short circuit allowed sufficient current flow to blow the twofuses in the DG-1 Control Circuit 4. A corrective action was to replace the faulty diodes. InNovember 2006, a plant modification (CED 6022440) removed the TVS circuits, whichincluded the subject diodes, and replaced them with a design that has prevented recurrenceof the failure described in the Condition Report.

c) For the out-of-specification ohm reading event, while performing Procedure 6.2DG.302, aresistance reading was not within the acceptance criteria of less than 1 ohm. Contacts wereburnished and relay contact resistance was satisfactory. These are wiping contacts. Thecondition, while not desirable, did not prevent the associated components from actuating.Thus, the required safety function would have been performed.

d) For the event involving testing indications for Terminal Block YW points 4 and 5 beingabove acceptance criteria values, while performing Procedure 6.2DG.302, a resistancereading was not within the acceptance criteria of less than 1 ohm. Resistance was re-measured and was less than 1 ohm (this indicated that the 52/b contact on Breaker 1GB inBreaker 1 GS closing circuit was closed). This satisfactory re-measurement indicates thatthis condition was not a component failure.

e) For the event involving the inability to unload DG-1 to 1000 kW, failure of DG-1 governorcontrols and Digital Reference Unit occurred during adjustment of DG-I load using


governor controls performed per Procedure 6.1DG.302 during testing to satisfy the 18-month requirement of SR 3.5.1.9.

The DG-1 governor controls are also used to vary DG-1 load under Procedure 6.1DG.101,"Diesel Generator 31 Day Operability Test (IST) (DIV 1)" which satisfies SR 3.8.1.3 (31day requirement to verify synchronization and loading of each DG). Performance of the testalso satisfies various other 31 day and 92 day SRs. The DG- 1 governor controls are alsoused to vary DG-1 load under Procedure 6.1DG. 102, "Diesel Generator Demonstration ofOperability Test (DIV 1)." Performance of the test satisfies various 31 day, 92 day and 184day SRs. Accordingly, this failure would have been detected by the more frequent testsassociated with DG operability tests (Procedures 6.1DG. 101 and 6.1DG. 102).

In summary, for each case, a more detailed review of the identified circuit failures has concludedthat they are unique and non-recurring (including resolution through modification), or that thefailures would not have prevented the required Technical Specification safety function, or thatthe failed components are subject to more frequent testing and would have been identified.Accordingly, SR 3.5.1.9 may be safely extended from 18 months to 24 months without concernfor undetected failures during this extended surveillance interval.


Attachment 2

List of Regulatory Commitments

Correspondence Number: NLS2012033

The following table identifies those actions committed to by Nebraska Public Power District inthis document. Any other actions discussed in this submittal are provided for informationpurposes and are not considered to be regulatory commitments.

TYPE(Check one) SCHEDULED

COMMITMENT/COMMITMENT NO. ONE-TIME CONTINUING COMPLETION

ACTION COMPLIANCE DATE

NPPD will supplement the 24-Month CycleLicense Amendment Request to revise theSR 3.8.4.8 18-month frequency to 12 X 6/2/2012months, consistent with IEEE 450-1995.[NLS2012033-01]

NLS2012033Enclosure 1Page 1 of 5

Enclosure 1

Affidavit from General Electric RequestingNEDC-31336 Be Withheld From Public Disclosure

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S~iBEcT PENRAL~LETRiC CoMPANY AFFJAVIT SUM.JITAL.

Per' phone4 requt of A4er .tanky enlsdi ee~ ledtriAffiavitto potec therefe~ncd' ret originally s. bMitt-e- oth R

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GENERAL ELECTRIC C" :LANY

AFFIDAVIT

I, DAVID 3. ROBARE, being duly sworn, depose and state as follows:1. I am Manager, Plant Licensing Services, Genera. Electric Company, and

have beT. delegated the function of reviewing the information describedin paragraph .2 which is sought to be, withheld and -have- been authorizedto apply for its withholding.

2. The information sought to be withheld is contained in.General ElectricReport NEDC -31336, "General.Electric -nstrument Setpoiit Methodology",dated October. 1986. The. GE Proprietary portions of this report areidentifi'able by.the NGE Proprietary Information" designation at the topof the page,

3. In designating material as proprietary, General Electric utilizes thedefinition of proprietary information and trade secrets.set forth inthe American Law Institute's Restatement of Torts:, Section 757. Thisdefinition:provides:

-"A trade secret may consist of any.formula,. pattern,. 4device or

compilation:, of informnation whitch is used in one's business and, whichgives him an opportunity to obtain an advantage over competitors whodo" not know or use it. .A substantlaelemnt of ..secrecy must exist,-

so. that, except, by.the f there would bedifficulty in acquiring information..- soe factors to be. considered

in determining whether given information is. one's strade secret are(1) the extent to which the 6.:for•tion is. known outside of his

business;, .(2) the0extent.to w'Ac.;-it i known by employees and-others involved in his busines:; :3, - .,-'ten. of measures taKen byhim to guard the secrecy of6 _ýthe. iv)- ,-on;.(4) the value of theinforiation to him and:to his competitors; (5) theramount of effortor money expandedrby him developing the informati0n; (6), the ease or-difficulty with which the information could be properly acquired orduplicated by others."

4. Some examplesr o.f categories "of information- which fit into thedefinition of.Proprietary Information are:

a.. Information that discloses a, process, method or apparatus whereprevention of its use by.:General Electric.'s competitors without.icense from, General :Electric .constitutes a competitive economicadvantage over other companies; "

b. Info.ration consisting of supporting data.and analyses,.includingtestdata rel ati ve to a-prcess, methodor apparatucs,theapplication of which provide a competitive economic advantage, e g.,by optimZation :or improved marketability;',

SGENERL ELECTRIC COMPANY.

c. information -which if, usedi by .a ompetitor,:." would ..r)educe hi sexpenditures -of resources or improve his compet.itive position in the

S-design, manufacture, shipment, installation, assuranceof. quality orlicensig* of a similar ProduCt;

d. IofmatI .on- whi ch. reveals,: cost or Price information, productioncapacities., budget levels or commerciali .strate:qtes of Generl IElec~tric, :Its customers or suppliers;

.• e:: Information which reveals aspects of past, present or future Genera.Eectric0cus.tomerfunded development plans and programs of potentialcoiimnrcial value to General Electric;.

f. .- . f:"Informathion whichdiscloses patentable subject matter for which"it

mAY be desirable oobanpatent protect Ion;:g. Informatio ,whic General El•ectri c •Us treat as popr ieay..

accordi1ng to agreemeints_ With. othIer parties..

5. 1altial approval of proprietarmy treatmentof a-document. is. typicallymade by the Subsection Manage.r o the ori-i •ating component the", personwho Ismost likely to :be acquainted w it the value and sensitivity, of' ""." "tAhe Inforati on in relation to industt y. knowledge. Access to suchdocumnts within the Company is -limited aon a -ned to. kno" b..asiand s a

s ~ ~ ~ ~'uch ouet r c'rlietfe as proprietay6..P The pocedure. fo. approval of external release of: suc a do ument

typi cal ly r.eq• resreview by the-Sbsection Managr,. Project Manageri:. Principa, scientist tor otherequivalent• aU•hority by the Subsection

manager of:-t, the "cognizant Marketing function: (or delegate) and by te.

Legal Operaion for technical c.ontent,; ompmetltivtiyefd eteri nation of the accuracy of the proprietary designation, In•,.

..accordance with the standards enumerated above Disciosures outsideGenierali Electric are g en .eraill lIimi-ted to' reg.qulator bo-diecstmr:.*.• . :::.::" nd ,potential.= .customers. and. their lagentssuppiers and- licensees then

'":olywith appropriate protection. by applicable regulatory provisions orporetary agreements.

The document men~~~~~tioned in paragraph,2aoehsbeneautdiacco-rdancewit tthe above cri ter ia and procedues and has been, foundto"contain iformation which i's proprietary and.which its customarily held

In con fidence by Genera Electric

8. The. nobripti on tol the best .of my knowledge6 anid elfhas consistently,bdeen. held i n confidence: by General Electric Company, no Pubic-:discl osre ýhas been mad e,: and ti o via i n pblic ources

4p

GENERAL ELECTRIC, COMIPANY

'AFFIDAVIT.

. 8. .All discosures. to thi rd parties have been made pursuant to regulatry"pro isions of proprietary agreemepts which provide for maintenance of:theinformation :in confidence..

P.blic di.. -sure o the i nformation oUight to be withheldis likely tocause substantial h-arm -to the •competiti ve psit on f Lthe .Gineal.Electr fCompany and depri r reduce.the availability of profi ..•.• '-:.:-.Amaking opportunities. A substantial effort-has been expended.by

General Electric to0develop this information.

GENERAL ELECTRIC.CO PANY'

AFFIDAVIT.

STATEOF CAIORZ

COUTY OF -AT CLA

:David J1 Robare,bing dul"sworn, deposes and says:

That he hasi read theiforegoing affidavit and. the pmatters stated therein are trulyandcorrect to th best of his knowledge,.iformation, anjibelief

Executed at San. Jose.. Cali fornia this __.. day ,of 'fV:i( 4 19 •

avd, . RoareGeneral Electric Company

Subscri bed an: sworn .before me thIs ti.day. of '. i'•C. .

o T-Ui~. SEAb )L~'L

Abk F1PAULA F HUJSSEY_______ _________

Notary: -Pub ic.. State 1f.4ifrn

m~y Comm. eyp4!sAR 3

I

NLS2012033Enclosure 3Page 1 of 4

Enclosure 3

NLS2011071 Replacement Pages

Replace the following pages from NLOS2011071:

Attachment 1, Page 18 of 35Attachment 2, Page 3.3-60Attachment 3, Page 3.3-60


3.1.4 Low-Low Set (LLS) Instrumentation

NUREG-0737 Item II.K.3.16 observed that the most likely cause of a small breakLOCA was from the opening of a Safety Relief Valve (SRV) where the SRV failed toreset. A reduction in this likelihood could be achieved by minimizing the number oftimes individual SRVs must recycle in performance of the system relief function. Inaddition, as part of the Mark I Containment Program, there was concern for potentialhigh thrust loads on the discharge piping and the high frequency pressure loading onthe containment. The LLS logic and instrumentation is designed to mitigate theabove concerns. Upon initiation, the LLS logic will assign preset opening andclosing setpoints to two preselected SRVs. These setpoints are selected such that theLLS SRVs will stay open longer (with a minimum blowdown range of 90 psi betweenSRV opening and closing); thus, releasing more steam to the suppression pool, andhence more energy (and time) will be required for repressurization and subsequentSRV openings.

One SRV is designated as the High LLS valve. Two pressure switches input into theLLS logic for this valve for opening and closing, respectively. A second SRV isdesignated as the Low LLS valve. Two different pressure switches similarly inputinto the LLS logic for opening and closing. The High LLS SRV is designed to openat a higher reactor pressure than the Low LLS SRV. Both SRVs are designed to closeat the same pressure.

The results of the drift analysis indicated that the projected 30-month drift values forthese pressure switches exceeded the drift allowance provided in the current setpointcalculation and were outside the current opening and closing TS Allowable Valuesfor the High and Low LLS SRVs. Accordingly, revised TS Allowable Values areproposed as follows:

LLS Existing Opening Revised Opening Existing Closing Revised Closing Analytical LimitSRV Allowable Value Allowable Value Allowable Value Allowable Value (psig)

(psig) (psig) (psig) (psig)High 1005 and• 1045 > 996.5 and• 1040 > 855 and: <895 >835 and < 875.5 Open < 1050

Close >_ 825Low _995 and < 1035 >966.5 and < 1010 > 855 and < 895 > 835 and < 875.5 Open < 1050

Close >: 825

As shown, these revised TS Allowable Values remain bounded by their respectiveAnalytical Limits and the 90 psi blowdown criterion.

3.2 TSTF-493, Revision 4, Option A Changes

The Technical Analysis for this application is described in TSTF-493 as referenced inthe NRC Notice of Availability published in the Federal Register on May 11, 2010(75 FR 26294). Plant-specific information related to the Technical Analysis is

I

I

LLS Instrumentation3.3.6.3

sable 3.3.6.3-1 Cps" i of1)LwLAsw got tnstnametstion

AMIOiN1SMVILLANII ALt@MILIEflWWMIU S AE

1. Reactor Pressure --I,1 I per ULI valve

2, LOw-Lo Set Pressure Setpoalits 2.per ILS valve

SR 3.3.6.3.3R 1.3.6.L34

R 3.3.6.3.553 3.3.6.3.3SR 3.3.6.3.4SR 3.3.6.3.5

3. DIschoaro Line Presure Sitch I per ARV SR 3.5.6.3.1 1 25 polg eW$4 3.3.6.3.2 55 PSI,SR 3.3.6.3.4M4 3.3.6.3.5

.9

'-KCooper 3.3-60 Amendment No. 178

LLS Instrumentation3.3.6.3

Table 3.3.6.3-1 (page 1 of 1)Low-Low Set Instrumentation

REQUIREDCHANNELS PER SURVEILLANCE ALLOWABLE

FUNCTION FUNCTION REQUIREMENTS VALUE

1. Reactor Pressure - High 1 per LLS valve SR 3.3.6.3.3 < 1050 psigSR 3.3.6.3.4SR 3.3.6.3.5

2. Low-Low Set Pressure Setpoints 2 per LLS valve SR 3.3.6.3.3 Low:SR 3.3.6.3.4 Open > 966.5 psigSR 3.3.6.3.5 and < 1010 psig

Close > 835 psigand < 875.5 psig

High:Open > 996.5 psigand < 1040 psig

Close > 835 psigand < 875.5 psig

3. Discharge Line Pressure Switch 1 per SRV SR 3.3.6.3.1 > 25 psig and < 55 psigSR 3.3.6.3.2SR 3.3.6.3.4SR 3.3.6.3.5

Cooper 3.3-60 Amendment No.

Documents

Nebraska Public Power District 50.90 Attn: Document ... · May 2, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Subject: Response