ML092310654

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Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application
ML092310654
Person / Time
Site: Cooper Entergy icon.png
Issue date: 08/28/2009
From: Bennett Brady
License Renewal Projects Branch 1
To: Minahan S
Nebraska Public Power District (NPPD)
BRADY B, NRR/DLR/RPB1, 415-2981
References
TAC MD9737, TAC MD9763
Download: ML092310654 (7)


Text

August 28, 2009 Mr. Stewart B. Minahan, Chief Nuclear Officer, Vice President - Nuclear Cooper Nuclear Station Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO.

MD9763 AND MD9737)

Dear Mr. Minahan:

The purpose of this letter is to transmit the request for additional information (RAI) B.1.20-1 which was inadvertently left out of the previous RAI letters and was discussed in our telephone conference on August 17, 2009. The staff has identified, in the enclosure, areas where this additional information is needed to complete the review of the Cooper Nuclear Station license renewal application.

This item in the enclosure was discussed with Mr. David Bremer. If you have any questions, please contact Bennett M. Brady at 301-415-2981 or by e-mail at Bennett.Brady@nrc.gov, or Tam Tran at 301-415-3617 or via e-mail at Tam.Tran@nrc.gov.

Sincerely,

/RA/

Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosure:

As stated cc w/encl: See next page

ML092310654 OFFICE PM:DLR:RPB1 LA:DLR PM:DLR:RPB1 BC:DLR:RPB1 PM:DLR:RPB1 NAME BBrady SFigueroa TTran DPelton BBrady (EKeegan for) (Signature)

(TTran for)

DATE 08/21/09 08/21/09 08/21/09 08/28/09 08/28/09

Letter to Stewart B. Minahan from Bennett M. Brady dated August 28, 2009

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION (TAC NO.

MD9763 AND MD9737)

DISTRIBUTION:

HARD COPY:

DLR RF E-MAIL:

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T. Tran E. Sayoc B. Brady F. Lyon I.Couret D. Roth (OGC)

A. Jones (OGC)

N. Taylor (RIV)

E. Collins (RIV)

C. Casto (RIV)

B. Maier (RIV)

V. Dricks (RIV)

D. Chamberlain (RIV)

A. Vegel (RIV)

W. Walker (RIV)

G. Miller (RIV)

G. Pick (RIV)

Cooper Nuclear Station cc:

Mr. Ronald D. Asche Deputy Director for Policy President and Chief Executive Officer Missouri Department of Natural Resources Nebraska Public Power District P.O. Box 176 1414 15th Street Jefferson City, MO 65102-0176 Columbus, NE 68601 Senior Resident Inspector Mr. Gene Mace U.S. Nuclear Regulatory Commission Nuclear Asset Manager P.O. Box 218 Nebraska Public Power District Brownville, NE 68321 P.O. Box 98 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Mr. John C. McClure 612 E. Lamar Blvd., Suite 400 Vice President and General Counsel Arlington, TX 76011-4125 Nebraska Public Power District P.O. Box 499 Director, Missouri State Emergency Columbus, NE 68602-0499 Management Agency P.O. Box 116 Mr. David Van Der Kamp Jefferson City, MO 65102-0116 Licensing Manager Nebraska Public Power District Chief, Radiation and Asbestos P.O. Box 98 Control Section Brownville, NE 68321 Kansas Department of Health and Environment Mr. Michael J. Linder, Director Bureau of Air and Radiation Nebraska Department of Environmental 1000 SW Jackson, Suite 310 Quality Topeka, KS 66612-1366 P.O. Box 98922 Lincoln, NE 68509-8922 Ms. Melanie Rasmussen Radiation Control Program Director Chairman Bureau of Radiological Health Nemaha County Board of Commissioners Iowa Department of Public Health Nemaha County Courthouse Lucas State Office Building, 5th Floor 1824 N Street 321 East 12th Street Auburn, NE 68305 Des Moines, IA 50319 Ms. Julia Schmitt, Manager Mr. Keith G. Henke, Planner Radiation Control Program Division of Community and Public Health Nebraska Health & Human Services R&L Office of Emergency Coordination Public Health Assurance 930 Wildwood Drive 301 Centennial Mall, South P.O. Box 570 P.O. Box 95007 Jefferson City, MO 65102 Lincoln, NE 68509-5007

Cooper Nuclear Station cc:

Mr. Art Zaremba, Director of Nuclear Mr. Dave Lach Safety Assurance LRP Entergy Project Manager Nebraska Public Power District Entergy Nuclear P.O. Box 98 1448 S.R. 333, N-GSB-45 Brownville, NE 68321 Russellville, AR 72802 Mr. John F. McCann, Director Licensing, Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601-1813 Mr. Mike Boyce Cooper Strategic Initiatives Manager Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321 Mr. Dave Bremer License Renewal Project Manager Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321 Mr. Bill Victor License Renewal Project Licensing Lead Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321 Mr. Jim Loynes License Renewal Project Engineer Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321 Mr. Garry Young License Renewal Manager Entergy Nuclear 1448 S.R. 333, N-GSB-45 Russellville, AR 72802 Mr. Alan Cox License Renewal Technical Manager Entergy Nuclear 1448 S.R. 333, N-GSB-45 Russellville, AR 72802

REQUEST FOR ADDITIONAL INFORMATION FOR COOPER NUCLEAR STATION UNITS 1 LICENSE RENEWAL Request for Additional Information (RAI) 3.5-1

Background:

In the license renewal application (LRA) Section 3.5.2.2.1.1, Section 3.5.2.2.1.2, Section 3.5.2.2.1.4, Section 3.5.2.2.1.10, Section 3.5.2.2.2.1, Section 3.5.2.2.2.2, and Section 3.5.2.2.2.4, the applicant stated that there are no aging effects requiring management for Cooper Nuclear Station (CNS) concrete due to the following:

1. Concrete is designed in accordance with ACI 318-63
2. The CNS below-grade environment is not aggressive Issue:

The staff is unable to verify the applicant claims due to lack of supporting data and/or information in the LRA in the following areas:

1. Air-entrained value and water-cement ratio
2. Data for below-grade water chemistry Request:

In order to complete the staffs review, additional information is needed as follows:

A. Provide supporting data/information for the above items.

B. Explain what action will be taken for inaccessible areas, if degradation (as a source of aging effects) is discovered in accessible areas? Will this involve additional commitments?

  • Explain why there are no aging effects requiring management for CNS concrete (both accessible and inaccessible) while the Generic Aging Lessons Learned (GALL) Report recommends the Structures Monitoring Program and/or a Plant-Specific Program to manage concrete aging effects for LRA Section 3.5.2.2.1.2, Section 3.5.2.2.2.1, and Section 3.5.2.2.2.4.

RAI 3.5.2.2.2.2-1

Background:

Standard Review Plan (SRP) Section 3.5.2.2.2.2, Aging Management of Inaccessible Areas, consists of five sub-sections to review as follows:

1. Loss of Material (spalling, scalling) and cracking due to freeze-thaw in below grade inaccessible concrete areas for group 1-3, 5, and 7-9 structures.
2. Cracking due to expansion and reaction with aggregates could occur in below-grade inaccessible concrete areas for group 1-5, and 7-9 structures.
3. Cracks and distortion due to increased stress levels from settlement and reduction of foundation strength, cracking, and differential settlement due to erosion of porous concrete subfoundation could occur in below-grade inaccessible concrete areas of groups ENCLOSURE

1-3, 5 and 7-9 structures.

4. Increase in porosity and permeability, cracking, loss of material due to aggressive chemical attack.
5. Increase in porosity and permeability, and loss of strength due to leaching of calcium hydroxide.

Issue:

LRA Section 3.5.2.2.2.2 states that groups 1-3, 5 and 7-9 inaccessible concrete areas provided in accordance with specification ACI 318-63, Building Code Requirements for Reinforced Concrete and that concrete also meets requirements of later ACI guide 201.2R-77. The LRA further states that inspection of accessible concrete have not revealed degradation related to corrosion of embedded steel and that the below-grade environment is not aggressive. The LRA concludes that corrosion of embedded steel is not an aging effect requiring management for concrete (Reference to RAI 3.5-1). However, the staff was unable to complete its review because the LRA did not contain the related information for Sub-section 3.5.2.2.2.2.1 through Sub-section 3.5.2.2.2.2.5 of the SRP.

Request:

Provide the related information for Sub-section 3.5.2.2.2.2.1 through Sub-section 3.5.2.2.2.2.5 for the staff to review.

RAI 3.5.2.2-1

Background:

NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 1, states that the IWE Inservice Inspection Program should be supplemented and that additional appropriate examinations to detect stress-corrosion cracking (SCC) in bellows assemblies and dissimilar metal welds are warranted. In addition, Information Notice 92-20 describes instances of containment bellows cracking.

Issue:

LRA Section 3.5.2.2.1.7 states that the existing Containment Leak Rate and Containment Inservice Inspection - IWE Programs are adequate to detect cracking since the susceptible components are not subject to a corrosive environment. The staff could not determine the basis for this position.

Request:

The staff requests that the applicant provide a discussion on the augmented exams discussed in LRA Table 3.5-1, Items 10 and 11, and indicate how the exams will detect fine cracks.

RAI 3.5.2.2-2

Background:

NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 1, states that the IWE Inservice Inspection Program should be supplemented in that VT-3 visual inspection may not

detect fine cracks.

Issue:

LRA Section 3.5.2.2.1.8 states that the existing containment Leak Rate Program with augmented exams and Containment Inservice Inspection - IWE will be used to detect cracking.

LRA Section 3.5.2.2.1.8 and LRA Table 3.5.1, Items 12 and 13 refer to augmented inspections but do not provide a discussion on the specifics of the augmented inspections.

Request:

The staff requests that the applicant provide a discussion on the augmented inspections, and indicate how they will be used to detect fine cracks.

RAI 3.5.2.2.2.6-1

Background:

NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 1, Generic Item T-30, recommends the Structures Monitoring Program to manage loss of material and general corrosion.

Issue:

LRA Section 3.5.2.2.2.6.2 states that the Structures Monitoring Program manages loss of material for steel structural components. The LRA further states that for some components the Fire Protection Program supplements the Structures Monitoring Program and, for other components, the Periodic Surveillance and Preventive Maintenance, Fire Protection, or Fire Water System Programs be used to manage the loss of material. The staff could not determine how the above mentioned programs meet or exceed the Structures Monitoring Program.

Request:

The staff requests that the applicant provide a comparison of the above mentioned programs to the Structures Monitoring Program and specify how the programs will meet or exceed the requirements of the Structures Monitoring Program, relative to the aging effect loss of material/general and pitting corrosion.

RAI 3.5.2.2.2.6-2

Background:

NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 1, Generic Item T-29, includes grouted anchors and grout as components/material which should be managed by the Structures Monitoring Program.

Issue:

LRA Section 3.5.2.2.2.6.1 states that the Structures Monitoring Program will confirm the absence of aging effects for CNS concrete components, but does not discuss grouted anchors.

Request:

The staff requests that the applicant discuss whether grout and grouted supports are included within the Structures Monitoring Program. In addition, if grout and grouted supports are not included within the Structures Monitoring Program, provide a discussion on how aging effects will be managed.

RAI 3.5.2.2.2.6-3

Background:

LRA Section 3.5.2.2.2.6.3 states that the CNS aging management review did not identify any component support structure/aging effect combination corresponding to NUREG-1801 Volume 2 Item III.B4.2-a.

Issue:

The staff could not determine whether vibration isolation elements exist at CNS and are included within the scope of license renewal, or whether the applicant has determined that vibration isolation elements included within the scope of license renewal have no aging effect.

Request:

The staff requests that the applicant indicate whether or not vibration isolation elements are included within the scope of license renewal at CNS. If vibration isolation elements are included within scope the scope of license renewal, provide a basis for why they are not covered by the Structures Monitoring Program.

RAI 3.5.2.3-1

Background:

GALL Report, Revision 1, Generic Item TP-6, says stainless steel support members and bolted connections in an outdoor environment should be monitored by the Structures Monitoring Program for the aging effect loss of material.

Issue:

LRA Table 3.5.2-4 lists five stainless steel support and bolting component groups in an air-outdoor environment. The LRA lists the aging effect and aging management program as none and refers to Note I and Note 503, which state that aging management is not required for stainless steel components exposed to the external environment because the environment at CNS is not chemically polluted. The staff did not determine that Note 503 is adequate to conclude that aging management is not required for these components.

Request:

Provide a basis for the conclusion that no aging effect is applicable to the above mentioned component groups and why the component groups were not included in the Structures Monitoring Program.