ML092380434

07/07/2009 Meeting Summary, Telephone Conference Call Between the U.S. NRC Staff and Nebraska Public Power District, Related to a Clarification for Certain Requests for Additional Information, for Cooper Nuclear Station License Renewal

ML092380434
Person / Time
Site:	Cooper
Issue date:	09/17/2009
From:	Tam Tran License Renewal Projects Branch 1
To:	Nebraska Public Power District (NPPD)
SAYOC E, NRR/DLR/RPB2, 415-1924
References
Download: ML092380434 (11)

Text

September 17, 2009 LICENSEE: Nebraska Public Power District FACILITY: Cooper Nuclear Station

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JULY 7, 2009, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND NEBRASKA PUBLIC POWER DISTRICT, RELATED TO A CLARIFICATION FOR CERTAIN REQUESTS FOR ADDITIONAL INFORMATION FOR COOPER NUCLEAR STATION LICENSE RENEWAL The U.S. Nuclear Regulatory Commission staff and representatives of Nebraska Public Power District held a telephone conference call on July 7, 2009, to discuss clarifications for certain draft requests for additional information for Cooper Nuclear Station license renewal. provides a listing of the participants, and Enclosure 2 contains a brief description of the conference call.

The applicant had an opportunity to comment on this summary.

/RA/

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

Enclosures:

As stated cc w/encls: See next page

ML092380434 OFFICE LA:DLR PM:RPB1:DLR PM:RPB2:DLR BC:RPB1:DLR PM:RPB2:DLR NAME I. King B. Brady T. Tran D. Pelton T. Tran (Signature)

DATE 09/03/09 09/04/09 09/14/09 09/17/09 09/17/09

Memorandum to Nebraska Public Power District from Tam Tran dated September 17, 2009

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JULY 7, 2009, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND NEBRASKA PUBLIC POWER DISTRICT, RELATED TO A CLARIFICATION FOR CERTAIN REQUESTS FOR ADDITIONAL INFORMATION FOR COOPER NUCLEAR STATION LICENSE RENEWAL 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. Alan Cox Safety Assurance License Renewal Technical 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 Mr. Dave Lach Licensing, Entergy Nuclear Northeast LRP Entergy Project Manager Entergy Nuclear Operations, Inc. Entergy Nuclear 440 Hamilton Avenue 1448 S.R. 333, N-GSB-45 White Plains, NY 10601-1813 Russellville, AR 72802 Mr. Mike Boyce Mr. Stewart B. Minahan Cooper Strategic Initiatives Manager Vice President Cooper Nuclear Station Nuclear and Chief Nuclear Officer 72676 - 648A Avenue Cooper Nuclear Station Brownville, NE 68321 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

LIST OF PARTICIPANTS TELEPHONE CONFERENCE CALL COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION JULY 7, 2009 PARTICIPANTS AFFILIATIONS Tam Tran U.S. Nuclear Regulatory Commission (NRC)

Brian Harris NRC Abdul Sheikh NRC Emmanuel Sayoc NRC On Yee NRC Seung Min NRC Ganesh Cheruvenki NRC Albert Wong NRC Dave Bremer Nebraska Public Power District (NPPD)

Jim Loynes NPPD Scott Freborg NPPD Dave Lach Entergy Nuclear Operations, Inc. (Entergy)

Alan Cox Entergy Don Fronabarger Entergy Andrew Taylor Entergy ENCLOSURE 1

COOPER NUCLEAR STATION POWER PLANT LICENSE RENEWAL APPLICATION (Brief description of the conference call)

The U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Nebraska Public Power District (NPPD) held a telephone conference call on July 7, 2009, to discuss clarifications for certain draft requests for additional information related to the Cooper Nuclear Station (CNS) license renewal application listed below.

Draft Request for Additional Information (D-RAI) B.1.9-4

Background

According to Generic Aging Lessons Learned (GALL) aging management review line Item IV B1-14, cumulative fatigue evaluation as part of a time-limited aging analysis (TLAA) for core shroud components is recommended.

Issue In Section 5.5 of the applicants report CR-CNS-07-LRD04, CNS Licensing Renewal Project -

TLAA-Mechanical Fatigue, the applicant stated that the fatigue evaluation of the core shroud components is not based on the life of the plant, and therefore, it is not a TLAA.

Request Provide an explanation for not performing a TLAA evaluation for the core shroud components.

If this is not a TLAA, how is the degradation due to fatigue managed for the core shroud components.

Discussion The applicant indicated that the question is clear. This draft RAI will be sent as a formal RAI.

D-RAI B.1.38-2

Background

License renewal application (LRA) Section B.1.38, Water Chemistry Control - Auxiliary Systems description states in part: Program activities include sampling and analysis of water in auxiliary condensate drain system components, auxiliary steam system components, and heating and ventilation system components to minimize component exposure to aggressive environments.

Under 3. Parameters Monitored/Inspected, it states in part: In accordance with industry recommendations, auxiliary condensate drain system and auxiliary steam system water parameters monitored are pH, conductivity, phosphate, sulfite, and iron. Furthermore, it also states that In accordance with industry recommendations, heating and ventilation systems parameter monitored is sodium nitrite (NaNO2).

Under 10. Operating Experience, it states in part: The results for the condensate and steam system indicated no variance limits in pH or conductivity with occasional variance in iron, phosphate and sulfite. Also, the results for the admin chiller system indicated no variance from limits in conductivity with occasional variance in sodium nitrites.

ENCLOSURE 2

Issue

• It is not clear to the reviewer the reason(s) why a plant-specific water chemistry control program is necessary for the auxiliary systems.

• The LRA did not include a reference to the aforementioned industry recommendations.

• The LRA did not provide details on the equipment operating characteristics (e.g., boiler pressure), parameter monitoring program (e.g., frequency of water samples being collected), or description on those incidences where the parameters (e.g., phosphate and sulfite for the boilers, and sodium nitrites for the admin chillers) exhibited variance and the associated corrective actions to return them within the limits.

Request Please provide:

1. A comparison between the plant-specific water chemistry control program and the closed-cycle cooling water system and the water chemistry program in NUREG-1801, Volume 2, and a justification as to why the GALL programs are not suitable for the auxiliary systems.

2. Any applicable reference(s) to the industry recommendations.

3. More details on (i) steam pressure, (ii) frequency of the water samples being collected, (ii) the nature, frequency of those incidences where variances had occurred, as well as the outcome and efficacy of the corrective actions.

RAI B.1.38-2 (Revised)

Background

LRA Section B.1.38, Water Chemistry Control - Auxiliary Systems description states in part:

Program activities include sampling and analysis of water in auxiliary condensate drain system components, auxiliary steam system components, and heating and ventilation system components to minimize component exposure to aggressive environments.

Under 3. Parameters Monitored/Inspected, it states in part: In accordance with industry recommendations, auxiliary condensate drain system and auxiliary steam system water parameters monitored are pH, conductivity, phosphate, sulfite, and iron. Furthermore, it also states that In accordance with industry recommendations, heating and ventilation systems parameter monitored is sodium nitrite (NaNO2).

Under 10. Operating Experience, it states in part: The results for the condensate and steam system indicated no variance limits in pH or conductivity with occasional variance in iron, phosphate and sulfite. Also, the results for the admin chiller system indicated no variance from limits in conductivity with occasional variance in sodium nitrites.

Issue

• It is not clear to the reviewer the reason(s) why a plant-specific water chemistry control program is necessary for the auxiliary systems.

• The LRA did not include a reference to the aforementioned industry recommendations.

• The LRA did not provide details on the equipment operating characteristics (e.g., boiler pressure), parameter monitoring program (e.g., frequency of water samples being collected), or description on those incidences where the parameters (e.g., phosphate

and sulfite for the boilers, and sodium nitrites for the admin chillers) exhibited variance and the associated corrective actions to return them within the limits.

Request Please provide more details on (i) steam pressure, (ii) frequency of the water samples being collected, (ii) the nature, frequency of those incidences where variances had occurred, as well as the outcome and efficacy of the corrective actions.

Discussion The first two bulleted questions are withdrawn and will not be sent as a formal RAI based upon discussion/clarifications between the applicant and the staff. The third bulleted question was discussed and is understood by the applicant and will be sent as a formal RAI.

D-RAI B.1.7-4

Background

The staff found that the American Society of Mechanical Engineers Code (ASME)Section XI, 2001 Edition, 2003 Addenda was used for the program elements, Acceptance Criteria and Corrective Actions, of the applicants program rather than the ASME Code Section XI, 1986 Edition as recommended by the GALL Report.

Issue The edition and addenda of the ASME Code Section XI that the applicant program uses in the program are different from those the GALL Report recommends.

Request Provide the justification for the programs use of a different edition and addenda of the ASME Code Section XI for the program elements.

Discussion The staff discussed with the applicant its description, "2001 Edition 2003 Addenda" and whether or not this means that the applicant's Code Edition and Addenda include the 2002 Addenda as well as 2003 Addenda. The applicant confirmed that the term 2001 Edition 2003 Addenda means that it includes Addenda 2002 and 2003.

D-RAI 3.3.1-1

Background

In the LRA, the GALL Report Reactor Water Cleanup System (RWCU) aging management program is not credited for the aging management of the stainless steel inter-granular stress corrosion cracking (IGSCC) in the RWCU system. Instead, the Water Chemistry Control Program in conjunction with the One-Time Inspection Program was credited to manage the aging effect. The approach of the applicant might cause no further periodic inspections on the RWCU System.

The GALL Report recommends the following three criteria should be met to discontinue the IGSCC inspection of the RWCU system piping welds outboard of the second isolation valve.

1. Satisfactory completion of Generic Letter (GL) 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance.

2. No IGSCC detected in RWCU piping welds inboard of the second isolation valve (ongoing GL 88-01 inspection).

3. No IGSCC detected in RWCU piping welds outboard of the second isolation valve after inspecting a minimum of 10 percent of the susceptible piping welds.

The LRA Table 3.3.1, Item 3.3.1-37, indicates:

• The applicant has complied with the requirements of GL 89-10.

• Portions of the RWCU System were replaced with a stress-corrosion cracking (SCC)-

resistant material.

• No significant indications of SCC were observed on the piping that was not replaced.

Issue It is not clear whether the applicant met all of the three criteria to discontinue the RWCU system inspections.

Request

1. Clarify whether all of the three criteria are met to discontinue the inspections of the outboard piping of the RWCU system.

2. If all of the three criteria are not met, clarify what inspections will be performed for the inboard and outboard portions of the RWCU system piping, respectively, over the extended period of operation.

Discussion The discussion between the applicant and the staff centered on the CNS current licensing basis (CLB) that reflects closure of the GL 88-01 inspection based on different criteria from GALL, that allowed for ceasing examination of RWCU outboard portions. In relation to criterion 2, the applicant stated that the piping inboard of the second isolation valve (four inches or greater, at or above 200 F) has been replaced with IGSCC-resistant material. It was not clear whether all relevant piping and piping welds inboard of the isolation valve were replaced including repaired welds (ex., weld overlay). The staff indicated that even in the case that all relevant inboard piping and piping welds were replaced based on the appellant's statement that the outboard piping has non-resistant material, the optional criteria involving criterion 1 and the use of non-resistant material cannot be claimed. A possible follow-up telephone conference was deemed possible.

D-RAI B.1.11-1

Background

Exemptions from 10 CFR Part 50 requirements and Operating License amendments only apply to the CLB and are time-limited. Consequently, citing approved exemptions or amendments cannot be used as a basis for taking exception to the GALL Report since they may not be renewed. Each exception to the GALL Report must be evaluated for NRC approval based on the technical bases that are associated with aging management regardless of whether there is an approved related exemption or amendment. Citing an exemption or amendment does not provide an acceptable basis to take an exception to the GALL Report.

Issue The CNS LRA takes three exceptions to the GALL AMP XI.S4, 10 CFR Part 50, Appendix J, which are supported by approved 10 CFR Part 50 exemptions or license amendments.

Request Provide the technical bases, as they relate to aging management, and without referencing any exemptions, for the exceptions taken to the 10 CFR Part 50, Appendix J GALL AMP.

Discussion Draft RAI 1.11-1 was withdrawn by the staff and will not be sent as a formal RAI based upon discussion/clarifications between the applicant and the staff.

Discussion The staff had a follow-up question in regards to the applicants response to B.1.29-1. The discussion clarified that although material-environment combinations biased at susceptible locations established the sampling population criteria (i.e., did not further segregate sample populations by each possible aging effect), the examinations would include criteria for evaluating all relevant aging effects at said susceptible locations. This question was resolved.