ML082740251
| ML082740251 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/03/2008 |
| From: | Lyon C Plant Licensing Branch IV |
| To: | Minahan S Nebraska Public Power District (NPPD) |
| Lyon, C F, NRR/DLPM, 415-2296 | |
| References | |
| GL-08-001, TAC MD7815 | |
| Download: ML082740251 (5) | |
Text
October 3, 2008 Mr. Stewart B. Minahan Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NO. MD7815)
Dear Mr. Minahan:
On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(f),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated September 11, 2008 (ADAMS Accession No. ML082610224), Nebraska Public Power District (NPPD, the licensee) submitted a request for extension to GL 2008-01 for Cooper Nuclear Station (CNS). In your letter, you stated that "NPPD evaluated the actions necessary to satisfy the nine-month response during the three-month response period and determined that all the actions within its control, including completion of necessary walkdowns, would be completed within the nine-month period. As such, a three-month response was not submitted to the NRC.
This decision was based, in part, on an internal determination that walkdowns within primary containment were not warranted given the inherent design of the piping and components, and confidence in the as-built configuration in relation to the as-designed configuration." You further stated that, "In order to be consistent with the current industry expectations, NPPD has determined that walkdowns within the CNS primary containment would be prudent to support the GL response. However, these walkdowns are not possible without a plant shutdown of sufficient duration to de-inert primary containment, erect scaffolding, remove piping insulation, and properly plan to minimize additional dose." You stated that system walkdowns within the scope
S. Minahan of GL 2008-01 could not be completed without an outage of sufficient duration for portions of the containment spray and residual heat removal systems.
In your letter dated September 11, 2008, NPPD made the following regulatory commitments:
NPPD will complete the necessary walkdowns within CNS primary containment during the next outage of sufficient duration or no later than the conclusion of RE-25 [the next refueling outage], tentatively scheduled to commence Fall 2009.
A follow-up submittal to the nine-month response will be provided to the NRC no later than 90 days following an outage of sufficient duration or the completion of RE-25.
The NRC staff reviewed your basis for not providing a three-month response, your proposed alternative course of action and commitments, and the associated basis for acceptance as provided in your letter dated September 11, 2008, and concluded that they are acceptable for CNS, with the exception of the clarifications and associated requests discussed below.
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the CNS fall 2009 refueling outage, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the CNS fall 2009 refueling outage.
For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, NPPD should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that NPPD's letter dated September 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specification Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.
S. Minahan This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed above.
If you have any questions regarding this matter, please contact me at 301-415-2296.
Sincerely,
/RA/
Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298 cc: See next page
ML082740251 *email dated OFFICE LPL4/PM LPL4/LA DSS/SRXB/BC PGCB/BC LPL4/BC LPL4/PM MMurphy MMarkley MThadani NAME FLyon GLappert GCranston(*) for FLyon DATE 10/02/08 10/2/08 9/30/08 10/03/08 10/3/08 10/3/08 Cooper Nuclear Station 08/18/08 cc:
Mr. Ronald D. Asche Senior Resident Inspector President and Chief Executive Officer U.S. Nuclear Regulatory Commission Nebraska Public Power District P.O. Box 218 1414 15th Street Brownville, NE 68321 Columbus, NE 68601 Regional Administrator, Region IV Mr. Gene Mace U.S. Nuclear Regulatory Commission Nuclear Asset Manager 612 E. Lamar Blvd., Suite 400 Nebraska Public Power District Arlington, TX 76011-4125 P.O. Box 98 Brownville, NE 68321 Director, Missouri State Emergency Management Agency Mr. John C. McClure P.O. Box 116 Vice President and General Counsel Jefferson City, MO 65102-0116 Nebraska Public Power District P.O. Box 499 Chief, Radiation and Asbestos Columbus, NE 68602-0499 Control Section Kansas Department of Health Mr. David Van Der Kamp and Environment Licensing Manager Bureau of Air and Radiation Nebraska Public Power District 1000 SW Jackson P.O. Box 98 Suite 310 Brownville, NE 68321 Topeka, KS 66612-1366 Mr. Michael J. Linder, Director Ms. Melanie Rasmussen Nebraska Department of Environmental Radiation Control Program Director Quality Bureau of Radiological Health P.O. Box 98922 Iowa Department of Public Health Lincoln, NE 68509-8922 Lucas State Office Building, 5th Floor 321 East 12th Street Chairman Des Moines, IA 50319 Nemaha County Board of Commissioners Nemaha County Courthouse Mr. Keith G. Henke, Planner 1824 N Street Division of Community and Public Health Auburn, NE 68305 Office of Emergency Coordination 930 Wildwood P.O. Box 570 Ms. Julia Schmitt, Manager Jefferson City, MO 65102 Radiation Control Program Nebraska Health & Human Services R & L Mr. Art Zaremba, Director of Nuclear Public Health Assurance Safety Assurance 301 Centennial Mall, South Nebraska Public Power District P.O. Box 95007 P.O. Box 98 Lincoln, NE 68509-5007 Brownville, NE 68321 Mr. H. Floyd Gilzow Mr. John F. McCann, Director Deputy Director for Policy Licensing, Entergy Nuclear Northeast Missouri Department of Natural Resources Entergy Nuclear Operations, Inc.
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