Letter Sequence Response to RAI |
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Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance, Acceptance, Acceptance
Results
Other: ML083030246, ML083330066, ML083640401, ML090220584, ML090650061, ML090720066, ML090720068, ML090830248, ML090860762, ML090930256, ML091070269, ML091170031, ML091830055, ML091880258, ML101040676, ML101050376, ML101270268, ML102010302, ML102020397, NLS2009099, SAMA Meteorological Anomaly Related to the Cooper Nuclear Station License Renewal Application
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MONTHYEARML0830302462008-09-24024 September 2008 Copper Nuclear Station, License Renewal Application, Appendix E, Environmental Report Project stage: Other ML0833300662008-12-19019 December 2008 Determination of Acceptability and Sufficiency for Docketing and Opportunity for a Hearing Regarding the Application from Nebraska Public Power District, for Renewal of the Operating License for the Cooper Nuclear Station Project stage: Other ML0901203602009-01-0909 January 2009 Safety Evaluation Report Project stage: Request ML0836404012009-01-21021 January 2009 Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process for License Renewal for the Cooper Nuclear Station Unit 1 (TAC No. MD9763 and MD 9737) LTR Project stage: Other ML0906500612009-02-0202 February 2009 Letter from Nebraska State Historical Society Regarding Cooper Nuclear Station License Renewal Project stage: Other ML0907506862009-02-25025 February 2009 Scoping and Process Public Meeting Sides of February 25, 2009 Project stage: Request ML0908400622009-02-25025 February 2009 Transcript of Cooper Nuclear Station License Renewal Pubic Meeting - Evening Session, February 25, 2009, Pages 1-41 Project stage: Meeting ML0908400632009-02-25025 February 2009 Transcript of Cooper Nuclear Station License Renewal Public Meeting - Afternoon Session, Wednesday, February 25, 2009, Pages 1-33 Project stage: Meeting ML0907200662009-02-25025 February 2009 Comment (1) of James Gerweck, on Behalf of the Richardson County, Nebraska, Emergency Management Agency, Supporting CNS License Renewal Project stage: Other ML0907200682009-02-27027 February 2009 Comment (3) of Ashtin Paris, on Behalf of the City of Rock Port, Supporting Nebraska Public Power District'S Cooper Nuclear Station License Renewal Project stage: Other ML0908607622009-03-0909 March 2009 Letter from the Nebraska Department of Natural Resources the Cooper Nuclear Station License Renewal Project stage: Other ML0907200672009-03-10010 March 2009 Comment (2) of Alan Richard, on Behalf of Pawnee City Development Corporation, Supporting Renewal of License for Cooper Nuclear Station Project stage: Request ML0908302482009-04-0303 April 2009 Environmental Site Audit Regarding Cooper Nuclear Station Unit 1 License Renewal Application (TAC MD9763 and MD9737) Project stage: Other ML0902205842009-04-0303 April 2009 Proposed Review Schedule Regarding the Application from Nebraska Public Power District for Renewal of the Operating License for the Cooper Nuclear Station Project stage: Other ML0909302562009-04-0909 April 2009 Audit Plan for Aging Management Program Site Audit Regarding Cooper Nuclear Station Unit 1, License Renewal Application (Tac No. MD9737) Project stage: Other ML0909103082009-04-14014 April 2009 Summary of Public Environmental Scoping Meeting Related to the Review of the Cooper Nuclear Station, Licensed Renewal Application Project stage: Meeting ML0910702692009-04-16016 April 2009 EPA Comment on the Cooper Nuclear Station License Renewal Application Project stage: Other ML0911700312009-04-28028 April 2009 Environmental Site Audit Regarding Cooper Nuclear Station Unit 1 License Renewal Application Project stage: Other ML0909704142009-04-30030 April 2009 Summary of Site Audit Related to the Review of the License Review Application for Cooper Nuclear Station, Unit 1 Project stage: Approval ML0911905972009-05-0101 May 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application (TAC No. MD9763 and MD9737) Project stage: RAI NLS2009039, Response to Request for Additional Information for License Renewal Application - Balance-of-Plant Scoping and Screening2009-05-28028 May 2009 Response to Request for Additional Information for License Renewal Application - Balance-of-Plant Scoping and Screening Project stage: Response to RAI ML0912000172009-05-29029 May 2009 Issuance of Environmental Scoping Summary Report Associated with the Staff'S Review of the Application by the Nebraska Public Power District, for Renewal of the Operating License for Cooper Nuclear Station Unit 1 Project stage: Approval ML0917500882009-06-0101 June 2009 CNS Lr - NDEQ 2009 Ambient Network Plan Project stage: Request ML0918300552009-06-0808 June 2009 Reply from Fish and Wildlife Service on Transmission Line for Cooper Nuclear Station License Renewal Project stage: Other ML0915303162009-06-0808 June 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI ML0917501182009-06-11011 June 2009 CNS Lr - Tornado Occurrences in Nemaha County, Ne 1950-2009 Project stage: Request ML0913803652009-06-15015 June 2009 Audit Report Regarding the Cooper Nuclear Station, Unit 1, License Renewal Application Project stage: Acceptance Review NLS2009040, Response to Request for Additional Information for License Renewal Application - Aging Management Programs2009-06-15015 June 2009 Response to Request for Additional Information for License Renewal Application - Aging Management Programs Project stage: Response to RAI NLS2009049, Response to Request for Additional Information for License Renewal Application - Section B and C2009-06-22022 June 2009 Response to Request for Additional Information for License Renewal Application - Section B and C Project stage: Response to RAI ML0916002892009-06-29029 June 2009 Request for Additional Information for Cooper Nuclear Station License Renewal Project stage: RAI ML0916002782009-06-29029 June 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI NLS2009048, Response to Request for Additional Information for License Renewal Application Severe Accident Mitigation Alternatives2009-07-0101 July 2009 Response to Request for Additional Information for License Renewal Application Severe Accident Mitigation Alternatives Project stage: Response to RAI ML0917503682009-07-0101 July 2009 Summary of Regulatory Audit Related to the Review of the License Renewal Application for Cooper Nuclear Station Project stage: Approval ML0918802582009-07-0808 July 2009 Environment Project Manager Change for the License Renewal of Cooper Nuclear Station Project stage: Other ML0918804782009-07-14014 July 2009 Request for Additional Information Project stage: RAI ML0919005022009-07-14014 July 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI ML0918804822009-07-14014 July 2009 Request for Additional Information for the Review of Cooper Nuclear Station License Renewal Application Project stage: RAI ML0918702982009-07-16016 July 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI ML0918703042009-07-16016 July 2009 License Renewal Request for Additional Information Project stage: RAI ML0921600842009-07-20020 July 2009 Notice of Diane Curran'S Withdrawal of Appearance Project stage: Request ML0920902762009-07-29029 July 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application (TACs MD9763 and MD9737) Project stage: RAI NLS2009055, Response to Request for Additional Information for License Renewal Application2009-07-29029 July 2009 Response to Request for Additional Information for License Renewal Application Project stage: Response to RAI NLS2009063, Response to Request for Additional Information for License Renewal Application2009-08-17017 August 2009 Response to Request for Additional Information for License Renewal Application Project stage: Response to RAI ML0919600402009-08-19019 August 2009 Summary of Regulatory Audit Related to the Review of the License Renewal Application for Cooper Nuclear Station Project stage: Approval ML0923106542009-08-28028 August 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI ML0926500572009-09-28028 September 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI ML0926809352009-10-0707 October 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI ML0927300142009-10-15015 October 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI NLS2009085, Response to Request for Additional Information on License Renewal Application2009-10-22022 October 2009 Response to Request for Additional Information on License Renewal Application Project stage: Response to RAI ML0929200192009-10-29029 October 2009 Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application Project stage: RAI 2009-04-09
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Category:Letter type:NLS
MONTHYEARNLS2024006, Response to Nuclear Regulatory Commission'S Request for Additional Information for Relief Request RC3-022024-01-25025 January 2024 Response to Nuclear Regulatory Commission'S Request for Additional Information for Relief Request RC3-02 NLS2024007, Emergency Plan Implementing Procedure 5.7.1, Revision 732024-01-16016 January 2024 Emergency Plan Implementing Procedure 5.7.1, Revision 73 NLS2024003, 30 Day Report - Unauthorized Disassembly of Liquid Scintillation Detector2024-01-15015 January 2024 30 Day Report - Unauthorized Disassembly of Liquid Scintillation Detector NLS2024004, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20232024-01-10010 January 2024 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2023 NLS2023053, ISFSI, Supplement to Exemption Request from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-30030 November 2023 ISFSI, Supplement to Exemption Request from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation NLS2023050, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation NLS2023045, Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program2023-11-15015 November 2023 Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program NLS2023051, Response to Nuclear Regulatory Commission Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2023-10-10010 October 2023 Response to Nuclear Regulatory Commission Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2023049, 10 CFR Part 21 Report Regarding HGA Relays2023-09-0606 September 2023 10 CFR Part 21 Report Regarding HGA Relays NLS2023029, License Amendment Request to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks2023-09-0606 September 2023 License Amendment Request to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks NLS2023047, Licensee Guarantees of Payment of Deferred Premiums2023-07-26026 July 2023 Licensee Guarantees of Payment of Deferred Premiums NLS2023033, 10 CFR 50.55a Relief Request RC3-022023-06-27027 June 2023 10 CFR 50.55a Relief Request RC3-02 NLS2023039, Preparation and Scheduling of Operator Licensing Examinations2023-06-0101 June 2023 Preparation and Scheduling of Operator Licensing Examinations NLS2023038, Nebraska Public Power District 2022 Financial Report2023-05-22022 May 2023 Nebraska Public Power District 2022 Financial Report NLS2023031, Annual Radiological Environmental Report2023-05-11011 May 2023 Annual Radiological Environmental Report NLS2023017, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2023-05-0303 May 2023 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2023018, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-0303 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling NLS2023030, Annual Radioactive Effluent Release Report2023-04-27027 April 2023 Annual Radioactive Effluent Release Report NLS2023007, Technical Specification Bases Changes2023-04-17017 April 2023 Technical Specification Bases Changes NLS2023027, Annual Report of Individual Exposure Monitoring2023-04-13013 April 2023 Annual Report of Individual Exposure Monitoring NLS2023021, Quality Assurance Program Changes2023-04-10010 April 2023 Quality Assurance Program Changes NLS2023020, Decommissioning Funding2023-03-29029 March 2023 Decommissioning Funding NLS2023019, Property Insurance Coverage2023-03-23023 March 2023 Property Insurance Coverage NLS2023010, Inservice Inspection OAR-1 Owner'S Activity Report for Cooper Nuclear Station2023-02-0909 February 2023 Inservice Inspection OAR-1 Owner'S Activity Report for Cooper Nuclear Station NLS2023005, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20222023-01-19019 January 2023 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2022 NLS2022054, Preparation and Scheduling of Operator Licensing Examinations2023-01-0505 January 2023 Preparation and Scheduling of Operator Licensing Examinations NLS2022055, Emergency Plan, Revision 812023-01-0404 January 2023 Emergency Plan, Revision 81 NLS2022053, CNS-2022-11 Post Exam Submittal2022-11-22022 November 2022 CNS-2022-11 Post Exam Submittal NLS2022050, Notification of Revision to Cooper Nuclear Station Emergency Response Data System Data Point Library2022-11-0909 November 2022 Notification of Revision to Cooper Nuclear Station Emergency Response Data System Data Point Library NLS2022048, Management Change and Correspondence Update2022-11-0101 November 2022 Management Change and Correspondence Update NLS2022047, Core Operating Limits Report, Cycle 33, Revision 02022-10-14014 October 2022 Core Operating Limits Report, Cycle 33, Revision 0 NLS2022042, 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2) Summary Report2022-10-0707 October 2022 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2) Summary Report NLS2022037, Emergency Plan, Revision 80, Summary of 50.54(q) Analyses2022-08-18018 August 2022 Emergency Plan, Revision 80, Summary of 50.54(q) Analyses NLS2022035, Evacuation Time Estimate Report for Cooper Nuclear Station2022-08-16016 August 2022 Evacuation Time Estimate Report for Cooper Nuclear Station NLS2022031, Licensee Guarantees of Payment of Deferred Premiums2022-07-19019 July 2022 Licensee Guarantees of Payment of Deferred Premiums NLS2022005, Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2022-06-16016 June 2022 Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements NLS2022025, Nebraska Public Power District Letter (NLS2022010) to U.S. Nuclear Regulatory Commission Dated April 5, 2022, Annual Report of Individual Exposure Monitoring2022-06-0606 June 2022 Nebraska Public Power District Letter (NLS2022010) to U.S. Nuclear Regulatory Commission Dated April 5, 2022, Annual Report of Individual Exposure Monitoring NLS2022016, Annual Radiological Environmental Report2022-05-10010 May 2022 Annual Radiological Environmental Report NLS2022020, Nebraska Public Power District, Cooper Nuclear Station, 2021 Financial Report2022-05-0202 May 2022 Nebraska Public Power District, Cooper Nuclear Station, 2021 Financial Report NLS2022014, Annual Radioactive Effluent Release Report2022-04-27027 April 2022 Annual Radioactive Effluent Release Report NLS2022010, Annual Report of Individual Exposure Monitoring2022-04-0505 April 2022 Annual Report of Individual Exposure Monitoring NLS2022009, Property Insurance Coverage2022-03-23023 March 2022 Property Insurance Coverage NLS2022011, Preparation and Scheduling of Operator Licensing Examinations2022-03-18018 March 2022 Preparation and Scheduling of Operator Licensing Examinations NLS2022004, Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Relief Request RR5-01, Revision 12022-02-0707 February 2022 Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Relief Request RR5-01, Revision 1 NLS2022003, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20212022-01-20020 January 2022 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2021 NLS2021067, ISFSI - Independent Spent Fuel Storage Installation Decommissioning Funding Plan2021-12-16016 December 2021 ISFSI - Independent Spent Fuel Storage Installation Decommissioning Funding Plan NLS2021069, Withdrawal of Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2021-12-15015 December 2021 Withdrawal of Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2021066, Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Alternative Request RI5-02, Revision 32021-12-10010 December 2021 Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Alternative Request RI5-02, Revision 3 NLS2021065, Clarification of Response to Nuclear Regulatory Commission'S Request for Additional Information for Alternative Request RS-012021-12-0606 December 2021 Clarification of Response to Nuclear Regulatory Commission'S Request for Additional Information for Alternative Request RS-01 NLS2021056, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2021-11-16016 November 2021 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements 2024-01-25
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Text
N Nebraska Public Power District
'Always there when you need us" 54.17 NLS2009100 December 21, 2009 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Request for Additional Information for the Review of Cooper Nuclear Station License Renewal Application Cooper Nuclear Station, Docket No. 50-298, DPR-46
References:
- 1. Letter from Tam Tran, U.S. Nuclear Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, dated November 19, 2009, "Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application (TAC No. MD9763 and MD9737)."
- 2. Letter from Stewart B. Minahan, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated September 24, 2008, "License Renewal Application" (NLS2008071).
Dear Sir or Madam:
The purpose of this letter is for the Nebraska Public Power District (NPPD) to respond to the Nuclear Regulatory Commission (NRC) Request for Additional Information (Reference 1) regarding the Cooper Nuclear Station License Renewal Application (LRA) (Reference 2). The response is provided in Attachment 1. Additionally, in a telephone conference call conducted on September 21, 2009, NPPD agreed to make certain additional commitments and LRA changes.
The commitments are addressed in Attachment 2, and the LRA changes are provided in .
Should you have any questions regarding this submittal, please contact David Bremer, License Renewal Project Manager, at (402) 825-5673.
COOPER NUCLEAR STATION A~
P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3817 / Fax: (402) 825-5211 wwAw.nppd.comrn 4z. ,
NLS2009100 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on I IA (Date)
Sincerely, BrianJ. 0'Grady Site Vice President
/WV Attachments cc: Regional Administrator w/ attachments USNRC - Region IV Cooper Project Manager w/ attachments USNRC - NRR Project Directorate IV- 1 Senior Resident Inspector w/ attachments USNRC - CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure NPG Distribution w/ attachments CNS Records w/ attachments
NLS2009100 Page 1 of 3 Attachment 1 Response to Request for Additional Information for License Renewal Application Cooper Nuclear Station, Docket No. 50-298, DPR-46 The Nuclear Regulatory Commission (NRC) Request for Additional Information (RAI) regarding the License Renewal Application (LRA) is shown in italics. The Nebraska Public Power District's (NPPD) response to this RAI is shown in block font.
NRC Request: RAIB.1.10-6 In the NPPDLetter NLS2009055, dated July 29, 2009, the applicantsubmitted response to RAI B.l.10-2 related to recoatingthe torus priorto or during the period of extended operation to reduce the corrosion rate. The applicantstated that NPPDdoes not havefirm plans to recoat the torus. However, NPPD will continue to inspect the torus prior to and during the period of extended operation as requiredby ASME Boiler and Pressure Vessel Code, Section XL, Subsection IWE. The indicationsfound during the inspectionswill continue to be evaluated to determine the needfor correctiveactions including, but not limited to, recoating.The last recoatingof areas within the torus was the result of the 2005 torus inspection.
The staff is concerned that the large number of repairs,excessive zinc depletion, andpitting at thousands of locations to the torus during the last 35 years indicate that the integrity of the torus coating cannot be relied upon during the period of extended operation. Normal life of the torus coating is 15-20 years and CNS torus has never been recoated. In addition, CNS internal documents concerningself assessment of the torus coating have previously recommended recoatingof the torus. Therefore, in orderto complete its review, the staff requests the applicant to provide detailedjustificationfor not making a commitment to recoat the toruspriorto the start ofperiod of extended operation. Based on site specific operatingexperience and thousands of repairsperformed during the last 35 years, it appearsthat the torus coating have significantly exceeded its useful life. The response should also include the following information.
- 1. How many repairshave been performed to the Cooper torus shell coating until now?
- 2. How many of these repairs were performed at locations where the torus base metal thickness had been reducedby greaterthan 10 percent?
- 3. How many of the repairsrequired augmented inspection (including UT examination) in accordancewith ASME Section X, subsection IWE Code, Table 2500-1? Articles IWE-3122.3.b, IWE 3200, IWE 3511.3 and IWE-2420 of the ASME Code requires augmented examination of the area containingflaw or degradationif the base metal thickness is reduced by greaterthan 10 percent.
- 4. The bottom half of interiorsurface is not easily accessiblefor visual examination.
Therefore, does CNS have any plans to perform UT examinationfrom the torus
NLS2009100 Page 2 of 3 exteriorsurface at a number of randomly selected locations to demonstrate with 95 percent confidence that 95 percent of the torus surface has base metal thickness greater than 90 percent of the nominal thickness? If no plans exist, explain the current inspectionplan and how the plan ensures the structuralintegrity of the torus, now and during the period of extended operation.
The staff needs the above information to confirm that the effects of aging of the torus will be adequately managed so that it's intendedfunction will be maintainedconsistent with the current licensing basisfor the periodof extended operationas requiredby 10 CFR 54.21(a)(3).
NPPD Response:
- 1. A total of approximately 2200 coating repairs have been made to the Coo er Nuclear Station (CNS) torus shell for a total recoated area of approximately 102 ft since implementing the ASME Code required inspections in 2001, as specified by 10 CFR 50.55a. These coating repair areas constitute about 0.8% of the torus underwater surface area of 12,850 ft2 .
- 2. Inspections have identified 18 pits where the nominal thickness has been reduced by greater than 10%. The CNS torus shell nominal wall thickness is 11/16"on the bottom half sections. Ten percent (10%) would equal 0.069". The maximum measured torus pit is about 0.092" or 13% of the nominal wall thickness. These pits were evaluated as acceptable.
- 3. None of the 18 pits that exceeded the 10% nominal wall thickness required augmented ultrasonic testing (UT) inspection in accordance with IWE-3511.3, which states "Supplemental examinations [UT] in accordancewith IWE-3200 shall be performed when specified as a result of the engineeringevaluation." CNS engineering evaluations, in accordance with IWE-3122.3, have not required augmented UT examinations due to the localized nature of the pitting as opposed to a large area of general wall thinning, which has not been observed at CNS. The pits were recoated to stop further degradation. CNS does perform augmented visual testing (VT) inspections of the wetted surfaces in accordance with Category EC once each inservice inspection (ISI) period, thus meeting the requirements of Table IWE-2500-1 for augmented examinations and IWE-2420 for successive inspections.
- 4. Acceptance of the examination areas based on a statistical confidence level of at least 95%,
(identified by ASME B&PV Code Section XI subsection IWE-2500(4)(a)) applies to those areas requiring augmented UT examinations. CNS torus shell examination results to date have not required augmented UT inspection. Accordingly, the CNS torus examination results have not been subject to the requirements of paragraph IWE-3511.3 of the Code.
NLS2009100 Page 3 of 3 The wetted portion of the torus (essentially 100% of the portion below the water level) is visually inspected using divers once each ISI period or about every other refueling outage.
The CNS Containment ISI CII-1WE Program has been effective at managing the effects of aging on the torus and maintaining its structural integrity. To date, less than 0.8% of the torus wetted area has warranted recoating since ASME Section XI examinations began in 2001. Using conservative CNS-specific criteria to evaluate and recoat torus pitting stops further degradation of those identified areas. Performing visual inspections of 100% of the wetted surface areas designated as Category EC at a frequency of once per ISI period in accordance with ASME Section XI Code requirements will provide the long term management of pitting degradation. The program conservatively assures the effects of aging will continue to be managed so that the torus will remain capable of performing its intended functions consistent with the current licensing basis through the period of extended operation.
NUREG-1801,Section XI.S 1 designates ASME Section XI, Subsection IWE as the recommended aging management program for steel containments. There are no Preventive Actions (such as a Service Level 1 coating) listed in the Evaluation and Technical Basis. As stated in Section B.1.10 of the LRA, the CNS Containment ISI Program, with enhancements, is consistent with the program described in NUREG-1801,Section XI.S1, ASME Section XI, Subsection IWE. The detailed operating experience provided above demonstrates that the CNS ISI Program has historically been effective in managing torus corrosion. Accordingly, there is reasonable assurance that this program will continue to provide effective aging management of the torus during the period of extended operation, without the precondition of recoating.
However, recoating remains an option, if warranted, to more efficiently manage the effects of aging based on future operating experience.
NLS2009100 Page 1 of 2 Attachment 2 Response to Miscellaneous Topics Regarding the License Renewal Application Cooper Nuclear Station, Docket No. 50-298, DPR-46 Dialogue has occurred with the Nuclear Regulatory Commission (NRC) staff based on previous responses to Requests for Additional Information (RAI). As documented in the summary of the telephone conference call conducted on September 21, 2009, these discussions have resulted in the need for the Nebraska Public Power District (NPPD) to make certain regulatory commitments which will be relied upon by the NRC. Consistent with NPPD standard practice, these commitments are addressed below so as to be formally entered on the Cooper Nuclear Station (CNS) docket.
- 1. NPPD will submit (or otherwise make available for NRC review and approval) a non-proprietary version (or a redacted version per 10 CFR 2.390) of an analysis of the core plate rim bolts that demonstrates their adequacy considering potential loss of pre-load through the period of extended operation. This will be provided at least two years prior to the period of extended operation. NPPD expects to implement this commitment by a generic analysis sponsored by the BWRVIP in collaboration with EPRI.
Reference:
Conference call conducted on September 21, 2009 (with a follow-up discussion on December 2, 2009), regarding the response to RAI 4.1-1.
- 2. NPPD will confirm that there are no niobium-bearing CASS materials used for vessel internal components, or provide a flaw evaluation methodology for niobium-bearing CASS internal components for staff review and approval. This will be provided at least two years prior to the period of extended operation. NPPD expects to implement this commitment by a generic analysis sponsored by the BWRVIP in collaboration with EPRI.
Reference:
Conference call conducted on September 21, 2009, regarding the response to RAI B.1.37-1.
- 3. NPPD will confirm there are no CASS materials with greater than 25% ferrite or provide a flaw evaluation methodology for CASS internal components with greater than 25%
ferrite for staff review and approval. This will be provided at least two years prior to the period of extended operation. NPPD expects to implement this commitment by a generic analysis sponsored by the BWRVIP in collaboration with EPRI.
Reference:
Conference call conducted on September 21, 2009, regarding the response to RAI B.1.37-2.
NLS2009100 Page 2 of 2 In the conference call, the CNS License Renewal Project staff expressed a willingness to make a commitment to perform neutron attenuation testing on an available Boral coupon once during the period of extended operation. Since that discussion, the NRC staff promulgated draft interim staff guidance (ISG) (LR-ISG-2009-01) on plant-specific aging management review and aging management program for neutron-absorbing material in spent fuel pools. This draft guidance is undergoing industry review and comment. As the draft ISG provides testing guidance that is different than what was being considered for CNS, it is inappropriate for NPPD to make this commitment prior to the NRC receiving industry comments. This was discussed with the NRC Staff during a conference call on December 2, 2009.
NLS2009100 Attachment 3 Page 1 of 2 Attachment 3 Changes to the License Renewal Application Cooper Nuclear Station, Docket No. 50-298, DPR-46 This attachment provides changes to the License Renewal Application (LRA) as agreed to in the September 21, 2009 conference call between the Nebraska Public Power District and the Nuclear Regulatory Commission (NRC) staff, as well as other miscellaneous changes. The changes are presented in underline/strikeout format.'
- 1. LRA Table 2.4-4, "Bulk Commodities Components Subject to Aging Management Review," is revised to add the following line item under "Other Materials":
Component Intended Function Roof Membrane Shelter or protection Support for Criterion (a)(2) equipment
Reference:
Clarification requested by the NRC Staff in a conference call conducted on September 21, 2009.
- 2. LRA Table 3.3.2-14-14, "Off Gas System, [10 CFR 54.4(a)(2)]," as revised in NLS20090952, Attachment 4, LRA Change 10, is revised to read:
Reference:
Correction.
- 3. LRA Table 3.5.2-4, "Bulk Commodities," is revised to include the following line item:
Roof EN Elastomer Air - Cracking Structures II.B4-7 3.5.1-16 E membrane SNS outdoor Change in Monitoring (C-18) material properties The changes shown are made against the original LRA submitted on September 24, 2008. Where other previously' made LRA changes affect the same text, a footnote is provided cross-referencing the letter where the previous change was made.
2 NLS2009095, Stewart B. Minahan to USNRC, Response to Request for Additional Information for License Renewal Application," November 30, 2009, RAI 2.3.3.12 OG-9.
NLS2009100 Page 2 of 2
Reference:
Clarification requested by the NRC Staff in a conference call conducted on September 21, 2009.