ML092680935

Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application

ML092680935
Person / Time
Site:	Cooper
Issue date:	10/07/2009
From:	Tam Tran License Renewal Projects Branch 1
To:	Minahan S Nebraska Public Power District (NPPD)
tran t, NRR/DLR/RPB1, 415-3617
References
TAC MD9737, TAC MD9763
Download: ML092680935 (8)

Text

October 7, 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:

By letter dated September 24, 2008, Nebraska Public Power District submitted an application pursuant to 10 CFR Part 54, to renew the operating license, DPR-46, for Cooper Nuclear Station for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and the associated Environmental Report submitted. The staff has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Mr. David Bremer. A mutually agreeable date for the response is within 30 days from the date of this letter, in order to maintain the license renewal review schedule. If you have any questions, please contact Bennett Brady at 301-415-2981 or by e-mail at bennett.brady@nrc.gov, or Tam Tran at 301-415-3617 or by e-mail at tam.tran@nrc.gov.

Sincerely,

\RA\

Tam Tran, 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

ML092680935 OFFICE PM:DLR:RPB2 LA:DLR PM:DLR:RPB2 BC:DLR:RPB1 PM:DLR:RPB2 NAME BBrady IKing TTran BPham TTran DATE 10/5/09 10/1/09 10/5/09 10/6/09 10/7/09

COOPER NUCLEAR STATION LICENSE RENEWAL REQUEST FOR ADDITIONAL INFORMATION RAI B.1.18-5

Background

In a letter dated June 15, 2009, Cooper Nuclear Station (CNS) responded to request for additional information (RAI) B.1.18-4, regarding the classification of the CHECWORKS software, which is used in the flow-accelerated corrosion program. CNS stated that CHECWORKS is classified as Level C, Business Important, based on being used to provide information to plant management for decision-making activities which do not affect the immediate ability to operate the plant yet could threaten long term operability. As justification for not classifying it as Level B Licensing Basis, the response stated that CHECWORKS is not used to verify continued compliance with regulatory requirements or commitments. According to CNS, its previous commitment, made in response to NRC Bulletin 87-01, regarding use of improved predictive models, was a one-time commitment to augment the [flow-accelerated corrosion] program, which had been implemented.

In reviewing the RAI response, the staff identified several clarification needed items which are listed below.

Issue By letter dated September 1, 1987, CNS responded to NRC Bulletin 87-01, Thinning of Pipe Walls in Nuclear Power Plants. The response indicated that the existing program would be enhanced to provide a systematic approach to the existing inspection, data collection, evaluation, and record retention methods. In addition, the response noted that the program to monitor pipe wall thinning would be augmented to include the use of improved predictive models in the selection of pipe inspection points, with scheduled implementation of these program improvements to be completed before the refueling outage in February 1988.

To support license renewal application (LRA) for extended operation, the applicant credits the enhancement of the program to monitor pipe wall thinning to be consistent with the generic aging lessons learned (GALL) report aging management program (AMP) recommendation. The enhancement consists of the use of improved predictive models in the selection of pipe inspection points, with scheduled implementation of these program improvements. The staff understands that, although initial implementation of improved predictive models is a one-time action, the use of the improved predictive models is not a one-time commitment, but rather a needed ongoing commitment for the program during the period of extended operation in order to maintain consistency with the GALL report AMP recommendation. This ongoing commitment includes Software QA associated with the use of computer codes for predictive modeling (e.g.,

CHECWORKS).

The ongoing nature of the use of predictive software appears to be reinforced in CNS letter dated July 13, 1989, in response to Generic Letter (GL) 89-08, Erosion/Corrosion - Induced Pipe Wall Thinning. The response stated that a long term erosion/corrosion program has been put in place at Cooper, that uses procedures and administrative controls which are equivalent

to those described in the NUMARC program. The NUMARC program described personal-computer based software that 1) ranked components in piping systems in order of susceptibility,

2) chose the most susceptible locations for inspections, and 3) used inspection data to develop a plant-specific model to predict the time to reach minimum required wall thickness.

In addition, the information provided in the LRA, for the Updated Safety Analysis Report Supplement, Section A.1.1.18, Flow-Accelerated Corrosion Program, indicates that this is an existing program, which is based on EPRIs recommendations in NSAC-202L report, that predicts, detects, and monitors flow-accelerated corrosion at CNS. NSAC-202L report recommends that a detailed flow-accelerated corrosion analysis be performed using a predictive methodology such as CHECWORKS, but also notes that any analytical tool that covers the necessary plant design, operating, and water chemistry conditions may be selected. Based on information obtained by the NRC staff during the regulatory audit of 4/20 - 4/24/09, CNS is currently using the CHECWORKS software as the analytical tool for the predictive methodology.

Hence, based on the combined information in its responses to Bulletin 87-01, and GL-89-08, and LRA Section A.1.1.18, CNS has an ongoing commitment to have a flow-accelerated corrosion program based on enhancement of the program to use CHECWORKS. The capability to analytically predict susceptible locations (e.g., CHECWORKS) is a necessary attribute of such a program that is discussed within referenced documents.

Although there is no requirement as to how this capability should be implemented, CNS chose to use the CHECWORKS software as the means to predict, detect, and monitor wall thinning in its flow-accelerated corrosion program.

Request Since the CHECWORKS software is not classified as Level B, Licensing Basis, as justified in the response to RAI B.1.18-4, the staff requests a description of how the flow-accelerated corrosion AMP will meet all applicable licensing basis requirements during the period of extended operation, specifically with respect to:

-using improved predictive models (e.g., CHECWORKS)

-being equivalent to the NUMARC program, and

-being based on EPRI recommendations in NSAC-202L.

RAI B.1.18-6

Background

CNS LRA, Section B.1.18, as modified by CNS letter dated June 15, 2009, states:

The Flow-Accelerated Corrosion (FAC) Program is an existing program that applies to safety-related and nonsafety-related carbon steel components and gray cast iron in systems containing high energy fluids carrying two-phase or single-phase high-energy fluid per the criteria given in EPRI NSAC-202L. [emphasis added by NRC]

Issue GALL Section XI.M17, Flow-Accelerated Corrosion, and NSAC-202L, Recommendations for an Effective Flow-Accelerated Corrosion Program, discuss steel, carbon steel, and low alloy steel components as those covered within the scope of the programs described therein.

However, neither document contains a discussion with regard to a flow-accelerated corrosion program being applicable to managing loss of material for gray cast iron components. Note that NSAC-202L report recommends a detailed flow-accelerated corrosion analysis be performed using a predictive methodology such as CHECWORKS, but also notes that any analytical tool that covers the necessary plant design, operating, and water chemistry conditions may be selected. Based on information obtained by the NRC staff during the regulatory audit of 4/20 -

4/24/2009, CNS is currently using the CHECWORKS software as the analytical tool for the predictive methodology in its flow-accelerated corrosion program.

Request (1) Explain how the CNS flow-accelerated corrosion program will effectively manage the relevant aging effects for gray cast iron.

(2) Provide information, including relevant operating experience, regarding the ability of the CHECWORKS software to reasonably predict flow accelerated corrosion for gray cast iron components.

Letter to S. Minahan from T. Tran, dated October 07, 2009 DISTRIBUTION:

SUBJECT:

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

MD9763 AND MD9737)

HARD COPY:

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T. Tran 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. Jim Loynes Safety Assurance License Renewal Project Engineer Nebraska Public Power District Cooper Nuclear Station P.O. Box 98 72676 - 648A Avenue Brownville, NE 68321 Brownville, NE 68321 Mr. John F. McCann, Director Mr. Garry Young Licensing, Entergy Nuclear Northeast License Renewal 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. Alan Cox Cooper Strategic Initiatives Manager License Renewal Technical Manager Cooper Nuclear Station Entergy Nuclear 72676 - 648A Avenue 1448 S.R. 333, N-GSB-45 Brownville, NE 68321 Russellville, AR 72802 Mr. Dave Bremer Mr. Dave Lach License Renewal Project Manager LRP Entergy Project Manager Cooper Nuclear Station Entergy Nuclear 72676 - 648A Avenue 1448 S.R. 333, N-GSB-45 Brownville, NE 68321 Russellville, AR 72802 Mr. Bill Victor License Renewal Project Licensing Lead Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321