ML101530128

Cooper Nuclear Station - Comments on Safety Evaluation Report with Open Items Related to License Renewal

ML101530128
Person / Time
Site:	Cooper
Issue date:	05/26/2010
From:	O'Grady B J Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2010051
Download: ML101530128 (21)

Text

N Nebraska Public Power District"Always there when you need us" NLS2010051 May 26, 2010 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555-0001

Subject:

NPPD Comments on Safety Evaluation Report with Open Items Related to the License Renewal of Cooper Nuclear Station Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. Letter from Brian E. Holian, U.S. Nuclear Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, dated April 6, 2010,"Safety Evaluation Report with Open Items Related to the License Renewal of Cooper Nuclear Station." 2. Letter from Stewart B. Minahan, Nebraska Public Power District, to U.S.Nuclear Regulatory Commission, dated September 24, 2008, "License Renewal Application" (NLS2008071).

3. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.Nuclear Regulatory Commission, dated April 28, 2010, "'Response to Open and Confirmatory Items from the Safety Evaluation Report Related to the License Renewal of Cooper Nuclear Station" (NLS2010044).

4. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.Nuclear Regulatory Commission, dated May 4, 2010, "Response to Open Items from the Safety Evaluation Report and Request for Additional Information Related to the License Renewal of Cooper Nuclear Station" (NLS2010050).

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District (NPPD) to provide comments on the Nuclear Regulatory Commission Safety Evaluation Report (SER) per Reference

1. This SER was prepared in response to the NPPD License Renewal Application (LRA) for Cooper Nuclear Station (Reference 2). The NPPD comments are itemized in Attachment

1. Attachment 2 contains certain changes to the LRA resulting from the review of this SER. References 3 and 4 were previously submitted relative to the SER Open and Confirmatory Items,. and should be considered as part of the NPPD comments on the SER.COOPER NUCLEAR STATION 4I/7 L P O. Box 98 / Brownville, NE 68321-0098 Telephone:

(402) 825-3811 / Fax: (402) 825-5211 ww,nppd.com NLS2010051 Page 2 of 2 Should you have any questions regarding this submittal, please contact David Bremer, License Renewal Project Manager, at (402) 825-5673.I declare under penalty o perjury that the foregoing is true and correct.Executed on 1 6 0 t,.(5ate)/Sincerely, Brian J. O'Gr ady Vice President-Nuclear and Chief Nuclear Officer/WV Attachments cc: Regional Administrator w/ attachments USNRC -Region IV Cooper Project Manager w/ attachments USNRC -NRR Project Directorate IV- l 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 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@

4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTSW 4 Correspondence Number: 'NLS2010051 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document.

Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments.

Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None____________

I _____ I ______4 4-t.4 .4 4 4.4 PROCEDURE 0.42 REVISION 24 PAGE 19 OF 26 NLS2010051 Attachment 1 Page 1 of 18 Attachment 1 NPPD Comments on Safety Evaluation Report with Open Items Related to the License Renewal of Cooper Nuclear Station Cooper Nuclear Station, Docket No. 50-298, DPR-46 NLS2010051 Attachment 1 Page 2 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number I General NLS2010044 and NLS2010050 have been submitted which address the Open Items of Section 1.5 and the Confirmatory Item of Section 1.6. If the responses to these Open and Confirmed Items are accepted by the Nuclear Regulatory Commission (NRC) staff, changes should be made to the NRC sections that describe these Open and Confirmatory Items.2 1-8/1.7 The text of the third License Condition does not reflect Revise to read: "The third license condition requires that all capsules that Cooper Nuclear Station (CNS) participates in the in the reactor vessel that are removed and tested meet the Boiling Water Reactor Vessel and Internals Program .r.u. ir.ts of Amer-iea Society for- Testing and Materials (BWRVIP) Integrated Surveillance Program (ISP). The (ASTM) E 185 82 to the extent practicable for the configuration of BWRVIP controls the schedule for capsule removal, not the specimens in the capsule. Capsule withdrawal schedule -All CNS. Recommend replacing text with similar verbiage capsules in the reactor vessel that are removed and tested must meet used in the recently issued Fitzpatrick renewed license, the test procedures and reporting requirements of the most recent NRC-approved version of the Boiling Water Reactor Vessel and Internals Proiect (BWRVIP) Integrated Surveillance Program (ISP)appropriate for the configuration of the specimens in the capsule.Any changes to the capsule withdrawal schedule, including spare capsules, must be approved by the staff prior to implementation, in accordance with 10 CFR Part 50, Appendix H. All capsules placed in storage must be maintained for future insertion.

Any changes to storage requirements must be approved by the staff." Basis for Change: Per License Amendment 201, CNS is part of the BWRVIP ISP, which should be reflected in the License Condition.

3 1-7/1.5 The last statement made in the paragraph describing Revise to read: "The applicant has not agreed to include perform Open Item 3.0.3.1 -1 warrants clarification, socket weld volumetric examinations nor commit to a plant specific program at CNS.""The applicant has not agreed to include socket weld nor commit to a plant-specific program at CNS." Basis for Change: Clarification The Nebraska Public Power District (NPPD) had not agreed to perform volumetric examination of socket NLS2010051 Attachment 1 Page 3 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number welds in the One-time Small Bore Piping Inspection Program. However, NPPD performs VT-2 examinations on small bore socket welds.4 2-15/2.1.4.3.1 The paragraph "Scoping for Regulated Events" is Revise to read: ",10 CFR 5 4. (a)(3) requires that plant SSCs with.quoted as being from the CNS License Renewal the scope of license renewal include SS, s relied on in Application (LRA) Section 2.1.1.3. However, the analyses or! plant evaluations to perform a function that dem.nstrfat quotation is not correct. compliance with the Commission's regulations for- fre protection 0 CFR 50.18), environmental qualification (1 0 CFR 50 .4 9), pressurizd thermal shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).For- each of these regulated events, a report was prepar-ed to provide input into the seeping and scr-eening processes.

Thiese reports (1)identified the systems and structures that are relied on for- eah of the regulated evenft, andor- (2) either- identified specific.

components, Or pr-ovided a r-efer-ence to the documentation to be used a nu o sefeen~g~

The scope of license renewal includes those systems, structures, and components relied on in safey analyses or plt evaluations to perform a fuinction that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 5 0.49). pressurized thermal shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63). This section discusses the approach used to identify the systems and structures within the scope of license renewal based on this criterion.

The systems and structures that perform intended functions in support of these regulated events are identified in the descriptions in Sections 2.3.2.4. and 2.5.Basis for Change: Incorrect quotation NLS2010051 Attachment 1 Page 4 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 5 2-15/2.1.4.3.1 The paragraph "Fire Protection" purports to have been derived from information in LRA Section 2.1.1.3.1.

However, none of this is from the CNS LRA.Recommend revision based on the information contained in the LRA.6 2-16/2.1.4.3.1 The second paragraph under "Environmental Qualification" is not derived from the CNS LRA.Recommend its deletion since it does not reflect information in the CNS LRA.7 2-17/2.1.4.3.1 Under the discussion of "Station Blackout," the last Revise to read: "The LRA fu4ther states that the applieant paragraph begins with the statement, "The LRA further determined the system intended functions supp.rting 10 CFR 50.63 states that..." What is stated in this sentence has already requi.ements based on information contained

i the CLB. Because a been stated in the paragraph above, which quotes the boundingary approach for scoping EIC equipment was used, and the LRA. Accordingly, this beginning sentence should be onsite EIC systems and electrical equipment contained in deleted. Also, the second sentence appears to be mechanical systems are included within the scope of license renewal incomplete.

by default." Basis for Change: Clarification 8 2-21/2.1.4.5.1 The quotation from LRA Section 2.1.1 is not a direct quotation.

Recommend revision to reflect the salient LRA Section 2.1.1 verbiage.9 2-21/2.1.4.5.2 In the second paragraph, the statement "The evaluation Revise to read: "The staff determined that the process was based on boundaries for mechanical systems were documented on the review of the USAR, DCDs, the plant equipment database, NRC license renewal boundary drawings that were created by docketed correspondence and documents, and plant drawings.

The marking mechanical piping and instrumentation evaluation boundaries for mechanical systems were documented on diagrams to indicate the components within the scope of license renewal boundary drawings that were created by marking license renewal." is not correct. The highlighted mechanical piping and instrumentation diagrams to indicate the components are those that are both in scope for license components within the scope of license renewal and subject to aging renewal and are subject to Aging Management Review. management review. The staff determined that components within the evaluation boundar .er reieed to determine whether or not they perform an intended funtion. Intended functions were established based on if a particular function of a component was NLS2010051 Attachment 1 Page 5 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number necessary to support the system functions that meet the scoping criteria." Basis for Change: Clarification 10 2-23/2.1.4.6.2 In the second paragraph, the term "screenhouse" is used.This is not used in the CNS LRA, the CNS Updated Safety Analysis Report (USAR), or in the Structures Aging Management Review. Is this referring to the"intake structure?" 11 2-35/2.3.1.1.1 In the next to last paragraph, first sentence reads: "The Revise to read: "Te RV acts as a boundary for neutrons as well.RV acts as a boundary for neutrons as well." While the The RV provides a barrier to the release of radioactive materials vessel will attenuate neutron flux it is not considered an from the core." actual boundary.

However, in conjunction with the remainder of the reactor coolant pressure boundary, it is Basis for Change: Clarification considered a barrier to the release of radioactive materials from the core.12 2-38/2.3.2.1.1 In the last paragraph second sentence the word "inertia" Revise to read: "The system can be aligned to provide water to the should be "intertie." "Fuel" is not needed in that fuel pool diffusers via the RHR-fuel-FPC inertia intertie." sentence.Basis for Change: Grammatical correction 13 2-50/2.3.3.6.2 The second paragraph, next to last sentence, states: Revise to read: "Therefore, since there is no intended function"Therefore, since there is no intended function associated with 10 CFR 54.4(a)(23), the 15,000-gallon fire system associated with 10 CFR 54.4(a)(2), the 15,000-gallon flushing tank and associated components were correctly excluded fire system flushing tank and associated components from the scope of license renewal and are not subject to an AMR." were correctly excluded from the scope of license renewal and are not subject to an AMR." The citation Basis for Change: Citation correction should be to 10 CFR 54.4 (a)(3), not 10 CFR 54.4(a)(2).

14 2-51 through 2- The 64 hose station listing starting with the bottom 53/2.3.3.6.2 paragraph on Page 2-51 is based on information provided in a conference call on October 6, 2009. The intent of the listing was to guide the NRC to where the NLS2010051 Attachment 1 Page 6 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number in-scope hose stations were on the LRA drawings, rather than to provide the exact locations in the plant. In that.light, four of the. in-scope hose stations should have their locations relisted (the three hose stations under Instrument Storage should be in the Control Building, and HV-61 FP-547 should be listed as being in the Controlled Corridor).

NPPD believes that this listing of hose stations is an unnecessary level of detail, which has not been submitted on the CNS docket. NPPD recommends deletion of the listing and revision of the introductory sentence to read: "The applicant provided discussed in a telephone conference call the LRA drawing numbers, and locations of interior hose stations 5 and the associated manual isolation valves, as shown below." 15 2-66/2.3.3.12 In the first full paragraph; components "AF-V-1 13" and Revise to read: "In its response to RAI 2.3.3.12 AR-1, dated August"AF-V-1 14" should be "AR-V-1 13" and "AR-V-1 14." 17, 2009, the applicant identified the two safety-related valves as ARF-V- 113 and ARF-V- 114." Basis for Change: NLS2009063 (ADAMS Accession Number ML092310146) 16 2-88/2.3.4.1.2 In the third paragraph, first sentence, "2.3.4.4-MS-2" should be "2.3.4.1 -MS-2." Typographical error.17 2-118/2.5.1.2 In the third paragraph, the first two sentences refer to the applicability of 10 CFR 50 Appendix A General Design Criterion (GDC) 17 to Part 54 scoping and screening.

It is not clear how the application of GDC 17 to CNS has a nexus to 10 CFR 54.4(a)(1)/(2)/(3) criteria.

Recommend deletion.

NLS2010051 Attachment 1 Page 7 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 18 3-2/3.0.1.1 The first paragraph contains the following sentence:

Revise to read: "The tables are essentially the same as Tables 1 through 6 in the GALL Report, except that the "ID" and "Type""The tables are essentially the same as Tables 1 through columns in the GALLaI4 Report haves been replaced by an "Item 6 in the GALL Report, except that the "Type" column in Number" column and the "Item-NumberRelated Generic Item" and the Gall Report has been replaced by an "Item Number" "Unique Item" columns in the GALL Report eoekm haves-been column and the "Item Number" in the GALL Report replaced by a "Discussion" column." column has been replaced by a "Discussion" column." The Generic Aging Lessons Learned (GALL) Report Basis for Change: Clarification Revision 1 no longer has a column labeled "Item Number." It is more correct to say that the "ID" and"Type" columns in the GALL have been replaced by the"Item Number" column. Also, the "Related Generic Item" and "Unique Item" columns in the GALL have been replaced by a "Discussion" column.19 3-3/3.0.1.2 The discussion on "Environment" should include a Revise to read: "Environment

-The fourth column lists the cross-reference to LRA Table 3.0-3. environments to which the component types are exposed. Internal and external service environments are indicated with a list of these environments in LRA Tables 3.0-1,_and 3.0-2, and 3.0-3." Basis for Change: Completeness 20 3-3/3.0.1.2 The last paragraph on the page contains the sentence, Revise to read: "The notes, identified by letters, "The notes, identified by letters, were developed by a an NEI work group and will be used in futur-e LRMAs are standard NEI work group and will be used in future LRAs." This notes based on NEI 95-10 Table 4-2-2." should refer to Appendix F of NEI 95-10.Basis for Change: Clarification 21 3-8/3.0.3.1.1 The next to last paragraph refers to "RAI B.34- L." NPPD has never responded to a Request for Additional Information (RAI) with that designator.

It appears that it should be listed as "B. 1.1-l ."

NLS2010051 Attachment 1 Page 8 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 22 3-19/3.0.3.1.7 The paragraph on Operating Experience does not Revise to read: "In a letter dated June 15, 2009, the applicant completely reflect the response to RAI B. 1.25-1 responded to RAI B. 1.25-1, indicating that as required for all aging provided in NLS2009040.

management programs, operating experience (plant and industry) is used to enhance program performance.

The discovery of abnormal water level in manholes with electric cables would be resolved under the corrective action program." Basis for Change: Clarification 23 3-19/3.0.3.1.7 The second paragraph under Operating Experience Revise to read: "Since these cables are de-energized, they do not appears to be a quote from the response to RAI B. 1.25- perform a license renewal intended function during recovery from 1, but the last line is not complete.

SBO." Basis for Change: Response to RAI B. 1.25-1 in NLS2009040 24 3-23/3.0.3.1.10 The Commitment Numbers with the prefix 3-26/3.0.3.1.11 "NLS2009071-...." are not correct. They should be 3-60/3.0.3.2.6 "NLS20098071

-..." 3-61/3.0.3.2.6 3-110/3.0.3.2.15 3-117/3.0.3.2.18 25 3-28/3.0.3.1.11 The third paragraph under Operating Experience states: Revise to read: "Based on discussions with the applicant, this proegram [One Time T ..... Small Bore Piping P ..... ....."Based on discussions with the applicant, this program previously examination of certain Class 1 small bore piping has been[One-Time Inspection

-Small Bore Piping Program] a part of the ISI Program." was previously a part of the ISI Program." Basis for Change: Clarification The One-Time Inspection

-Small Bore Piping Program is a new Aging Management Program (AMP). Although it uses some of the same inspection techniques as the Inservice Inspection (ISI) AMP, it is a separate and new program, and has never been part of the CNS ISI Program.

NLS2010051 Attachment 1 Page 9 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 26 3-33/3.0.3.1.13 The last paragraph infers that all heat exchangers in the Revise to read: "The applicant responded by letter dated June 15, Generic Letter (GL) 89-13 program are tested for heat 2009, indicating that heat transfer capabilities are tested for transfer capabilities.

This is not correct. apphea-b; e REC and RHR heat exchangers and that cleanliness and material integrity are verified by visual inspection for other The Reactor Equipment Cooling (REC) and Residual components." Heat Removal (RHR) heat exchangers are tested for heat transfer capabilities.

Basis for Change: Response to RAI B. 1.35-3 in NLS2009040 The Diesel Generator Lube Oil (DGLO), Diesel Generator Jacket Water (DGJW) and Diesel Generator (DG) Intercoolers are not tested for heat transfer capabilities because it is impractical to do so. Instead, the DGLO, DGJW and DG Intercoolers are inspected and cleaned on a periodic basis as allowed by GL 89-13.27 3-42/3.0.3.2.1 In middle of the third paragraph, "EPRI NP-506" should Revise to read: "Furthermore, the staff noted that a previous NRC be "EPRI NP-5067." determination of the interchangeability of EPRI NP-5067 was detailed..." Basis for Change: Response to RAI B.1.2-1 in NLS2009040 28 3-50/3.0.3.2.4 The last sentence in the last paragraph states the Revise to read: "The enhancement would entail replacement of the enhancement is to replace the plugs based on "structural plugs in core plate bypass holes based on their stuetura!

integrity integrity" when actually the LRA commitment states it qualified life (Commitment No. NLS2008071-04)." is based on "qualified life." Basis for Change: Commitment NLS2008071-04 in NLS2008071 29 3-55/3.0.3.2.4 The last sentence in the third paragraph misquoted Revise to read: "By letter dated March 25, 2010, the applicant Commitment NLS2009100-1 (Revision 1). provided commitment NLS2009100-1 (Revision

1) to pFevide submit (or otherwise make available for NRC review and approval)a complete propriet_.y version of the GE repeoM an analysis of the core plate rim bolts that demonstrates their adequacy considering potential loss of pre-load through the period of extended operation." Basis for Change: Commitment NLS2009100-1 (Revision

1) in NLS2009100 NLS2010051 Attachment 1 Page 10 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 30 3-58/3.0.3.2.5 The third paragraph on Page 3-58 states: Revise to read: "As an enhancement to the GALL Report AMP, the 3-59/3.0.3.2.5 applicant is determined to implement the following two-monitoring"First, if the CNS standby capsule is removed from the and trending enhancements prior to the period of extended RPV without the intent of testing it, the capsule will be operation.

First, if the CNS standby is removed frem the stored in a manner that maintains the capsule in a RPV without the intent of testing it, the capsule will be StOred ina condition which would permit its future use, including manner- that maintains the capsu.le in a ..ndition which would during the period of extended operation if necessary." permit its future use, including during the period of extended operation if ne.essary.

The second This enhancement will ensure CNS does not have a standby capsule. Moreover, the that the additional requirements that are specified in the final staff third License Condition described in Section 1.7 SE for the BWRVIP- 116 report will be addressed before the period subsumes the need to make this commitment should of extended operation." NPPD acquire one in the future. Accordingly, it is being deleted (see Attachment 2, LRA Changes I and Basis for Change: License Condition 3 subsumes the need to make 2). this enhancement.

In the fourth paragraph of Page 3-59, "Conclusion," the following conforming change should be made to make"enhancements" singular: "Also, the staff reviewed the enhancements and confirmed that the implementation of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report AMP to which it was compared." 31 3-61/3.0.3.2.6 In first sentence of the fifth paragraph, the commitment Revise to read: "In its response dated June 15, 2009, the applicant number is not correct, provided Commitment No. NLS20098071-05 (Revision

1) to performing..." Basis for Change: Commitment No. NLS2008071-05 (Revision

1) in NLS2009040 NLS2010051 Attachment 1 Page 11 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 32 3-88/3.0.3.2.10 The second paragraph, Item (a) states, "Specify the analysis method(s) used for computing CUF for all Class 1 components, and clarify whether or not any of the CUF values shown in LRA were calculated using non-conforming software, FatiguePro, which considers only a single component of a stress tensor instead of all six stress components in accordance with the ASME Code Section III Design Code." This is an inaccurate paraphrase of the wording in RAI B. 1.15-8.Recommend revising to reflect exact wording of the RAI.33 3-89/3.0.3.2.10 The third to last sentence of the second paragraph states: "It appears that the applicant has the HWC and NWC coverage periods transposed." As NPPD accounted for hydrogen water chemistry unavailability in calculating the ratios, the numbers were not transposed.

Recommend removing this statement from the SER.34 3-90/3.0.3.2.10 Under "Enhancement (a)" of Page 3-90, "USAR 3-93/3.0.3.2.10 Supplement" of Page 3-93, and Commitment 8 on Page A-6 A-6, the commitment to enhance the Fatigue Monitoring Program (NLS2008071-08 Revision 1) should incorporate Revision 2 provided in NLS2010044 for use of NUREG/CR-6909.

35 3-109/3.0.3.2.15 Enhancement 1 states: "LRA Section B. 1.20 states an Revise to read: "LRA Section B. 1.20 states an enhancement to the enhancement to the ISI -IWF Program "scope of ISI -IWF Program "scope of program" and "detection of aging program" and "detection of aging effects" program effects" program elements as follows: "The ISI -IWF Program will elements as follows: "The ISI -IWF Program will be be enhanced to include Class metal clad (MC) piping and enhanced to include Class metal clad (MC) piping and component supports."" component supports."" Basis for Change: LRA Section B. 1.20 The LRA used the term "Class MC." The words "metal clad" should be "metal containment," although neither term was included in the LRA.

NLS2010051 Attachment 1 Page 12 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 36 3-114/3.0.3.2.17 The last paragraph on 3-114 that rolls over to the top of Revise to read: "The effects of the recent bird infestation will not 3-115/3.0.3.2.17 page 3-115 is represented as a direct quote from the result in a long-term change to the bus duct external environment NPPD response to RAI B.1.22-2 in NLS2009040.

This that could cause degradation renderring the ......ed AMP is not a direct quote. ineffective that will not be adequately managed by the proposed MEB Program. Note The potentially degraded environment caused by the bird excrement could provide a corrosive environment for aluminum, steel, and steel alloy. However, beeause-the aging effect from this environment is loss of material, which is addressed for the period of extended operation license renewal by visual inspections performed in accordance with the metal-enclosed-d+ac4 bus program.Therefore, this operating experience would not impact the ability of the metal-enclosed bus program to provide reasonable assurance that the intended functions would be maintained during the period of extended operation." Basis for Change: Response to RAI B. 1.22-2 in NLS2009040 37 3-119/3.0.3.2.19 The citation of "NUREG-1802" in the last paragraph should be "NUREG-1801." 38 3-130/3.0.3.2.21 In several locations throughout this section the NRC states that the Water Chemistry Control -Closed Cooling Water Program is consistent with the GALL and that issues and RAIs were resolved.

However in the Conclusion Section, the Safety Evaluation Report (SER)states that "On the basis of its audit and review of the applicant's Water Chemistry

-CCW Program, including the applicant's responses to the RALs, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent.

In addition, the staff reviewed the exceptions and their justifications and determined that the AMP, with exception 1, would not be consistent with the GALL AMP XI.M21 because it does not include non-chemistry monitoring consisting of NLS2010051 Attachment 1 Page 13 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number inspection and nondestructive evaluations.

The staff concludes that the applicant has not demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation in accordance with 10 CFR 54.21 (a)(3)." The conclusion does not appear to be consistent with the preceding text for Section 3.0.3.2.21.

39 3-136/3.0.3.3.2 The last sentence of the third paragraph implies that Revise to read: "The applicant acknowledged LR-ISG-2007-02 in NPPD will implement the as-written interim staff LRA Section 2.1.3 and stated that it will implement the-I1G guidance.

That is not what NPPD stated in LRA Section guidance of a one timne inspection program prior- to the period e 2.1.3. exteaded operation for cable .o. ections not subj.ect to 10 CFR__50. 4 9 EQ requirements a one-time inspection program prior to the period of extended operation to confirm the absence of aging effects for applicable electrical cable connections." Basis for Change: LRA Section 2.1.3 40 3-313/3.5.2.3.7 In the third paragraph of this section, the SER states, Revise to read: "The staff finds that the applicant has not"The staff finds that the applicant has not demonstrated demonstrated that the effects of aging will be adequately managed that the effects of aging will be adequately managed so so that the intended functions will be maintained consistent with the that the intended functions will be maintained consistent CLB for the period of extended operation, as required by 10 CFR with the CLB for the period of extended operation, as 54.21 (a)(3)." required by 10 CFR 54.2 1(a)(3)." This conclusion is inconsistent with the preceding discussion.

Basis for Change: Consistency correction 41 3-320/3.6.2.2.3 The fourth paragraph has an error from the LRA that Revise to read: "The,161-kV overhead transmission conductors are was corrected in NLS2009061, Attachment 3, dated 886.4 336.4 thousand circular mils (MCM) 26/4 26/7 ACSR." August 13, 2009.Basis for Change: NLS2009061, Attachment 3, Change 9 42 3-322/3.6.2.2.3 The first bullet in the second paragraph requires a Revise to read: "336.4 336. MCM 26/7 ACSR: [ultimate strength correction.

14,050 lbs/heavy load 4,327 lbs] Initial design margin 69.2 percent" Basis for Change: Response to RAI 3.6-2 in NLS2009061 NLS2010051 Attachment 1 Page 14 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 43 3-323/3.6.2.2.3 The fourth sentence of the third paragraph has an error. Revise to read: "For 336.4 336. MCM and 397.5 MCM transmission conductors, the ratio between the heavy loading and the ultimate conductor strength...." Basis for Change: Response to RAI 3.6-2 in NLS2009061 44 3-324/3.6.2.2.3 The first sentence of the second paragraph states: "However, the staff noted that failures of Belleville washers (causing loose connections) were noted from industry OE, whereby hydrogen entrapment with plated steel washers caused embrittlement and stress cracking of the plated washer leading to loose connections." This statement was not part of RAI 3.6-3, and NPPD was not able to find the cited industry Operating Experience.

It is recommended that the NRC confirm the accuracy of the above statement or revise as necessary.

45 44/4.2.1.1 These sections have specific reference numbers (e.g., 4-5/4.2.1.2 "Reference 1"). However, there is no Chapter 4 4-34/4.6, 4.6.1.2 reference section. The references numbers in Appendix 4-36/4.6.2.2 D do not correspond to these reference numbers.4-37/4.6.3.1 46 4-16/4.3.1 The words in the last sentence of the second paragraph Revise to read: "The applicant stated that according to LRA Table do not match the wording of the response to RAI 4.3.1- 4.3-1, the projected number of startups for 60 years at CNS is 245, 10(a). which exceeds the 229 cycles analyzed for the FW nozzle and piping, but it does not exceed the 400 cycles analyzed for the other parts of the reactor vessel, except for- the FW nozzles, RPV intemals, and Class IN piping." Basis for Change: Response to RAI 4.3-10(a) in NLS2009061 NLS2010051 Attachment 1 Page 15 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 47 4-25/4.3.1.3.2 The first paragraph is nearly identical to the sixth paragraph on the previous page, except for the statement"...the applicant confirmed that its site is not an older vintage plant..." Consider deleting the paragraph or making it consistent with the sixth paragraph on Page 4-24.48 4-26/4.3.1.4.2 In the second paragraph of this section, the second and Revise to read: "According to LRA Table 4.3-1, the 60-year third sentences state: projected cycles are less than the-7,000 cycles 10 year design values.On this basis, the staff finds acceptable the applicant's claim that the"According to LRA Table 4.3-1, the 60-year projected TLAA for the B3 1.1 piping remains valid, in accordance with 10 cycles are less than the 40-year design values. On this CFR 54.21 (c)(1 )(i), during the period of extended operation basis, the staff finds the applicant's claim that the aeeeptable." TLAA for the B3 1.1 piping remains valid, in accordance with 10 CFR 54.2 l(c)(l)(i), during the Basis for Change: Not exceeding individual transient 40-year cycles period of extended operation acceptable." is not the basis for acceptability for B3 1.1 piping, per ASME B3 1.1.Limiting total cycles to below 7,000 is the required acceptance For the B3 1.1 piping, it is recommended that there be a criteria.nexus to not exceeding 7,000 cycles rather than the 40-year design values for the NRC acceptance criteria, consistent with wording on page 4-25.49 4-27/4.3.2.2 The third paragraph of this section states: Revise to read: "According to LRA Table 4.3-1, the 60-year projected cycles are less than the 10 year design values7,000 cycles."According to LRA Table 4.3-1, the 60-year projected Therefore, the staff finds the applicant's claim that the TLAA for the cycles are less than the 40-year design values, non-Class 1 piping remains valid during the period of extended Therefore, the staff finds the applicant's claim that the operation acceptable." TLAA for non-Class 1 piping remains valid during the period of extended operation acceptable." Basis for Change: Not exceeding individual transient 40-year cycles is not the basis for acceptability for non-Class 1 piping, as described For the non-Class 1 piping, it is recommended that there in LRA Section 4.3.2. Limiting total cycles to below 7,000 is the be a nexus to not exceeding 7,000 cycles rather than the acceptance criteria.40-year design values for the NRC acceptance criteria, consistent with wording in the previous paragraph.

NLS2010051 Attachment 1 Page 16 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number 50 4-28/4.3.3.2 In the fourth paragraph of this section, the statement is made: "As indicated by the applicant, the use of an inspection program to manage fatigue will require prior staff review and approval." The LRA B. 1.15, Fatigue Monitoring Program (with Enhancements) tracks the number of critical thermal and pressure transients for selected reactor coolant system components.

It is not an inspection program and NPPD has not indicated that fatigue would be managed by any other inspection program requiring staff review and approval.

Recommend deletion of this sentence.51 4-30/4.3.3.2 The description in the third paragraph for Confirmatory Item (CI) 4.3.3.2-1 does not match the description of the CI on Page 1-8 (the CI on Page 1-8 does not specifically list the 1.49 Fen value but requires demonstration of adequate conservatism).

Recommend reconciling the CI wording.52 4-31/4.4 The first and second paragraphs of this section require Revise to read. "The 10 CFR 50.49 Environmental Qualification clarification.

Time-Limited Aging Analyses (TLAA) (EQ) program will manage the aging effects associated with time-are not programs or components, they are analyses.

As limited aging analyses (TLAAs) for environmental qualification of stated in the LRA Section 4.4, "Equipment qualification electric equipment for the period of extended operation in evaluations for EQ components that specify a accordance with 10 CFR 54.2 l(c)(l)(iii).

is a TLAA for purposez o qualification of at least 40 years, but less than 60 years, license renewal. Equipment qualification evaluations for EQ are considered TLAA for license renewal." components that specify a qualification of at least 40 years, but less than 60 years, are considered TLAA for license renewal. These The characterization that Environmental Qualification TLAAs for othe EQ of electrical components includes a14 analyses (EQ) TLAAs include "long-lived" electrical for leng-li-ved, passive; and active electrical instrumentation and components is not correct. The LRA states: "CNS control (EIC) components that are important to safety and are electrical cables and connections subject to 10 CFR located in a harsh environment.

50.49 EQ requirements are not subject to aging NLS2010051 Attachment 1 Page 17 of 18 Comment Page Number/ Comment Suggested Resolution Number Section Number management review since the components are subject to The applicant shall demonstrate that for each type of-EQ equipment replacement based on qualified life." This is also true TLAA, one of the following is true:..." for EQ components other than cables and connections.

Basis for Change: Clarification 53 4-32/4.4 The first sentence of the first paragraph should be Revise to read: "LRA Section 4.4 summarizes the applicant's clarified to refer to time-limited aging analyses, rather evaluation of TLAAs for the EQs-of-electric equipment for the than environmental qualifications, period of extended operation and..." Basis for Change: Clarification 54 4-36/4.6.2.1 The last sentence of the first paragraph states: Revise to read: "Therefore, main vent intersection with the vent header, vent header miter joint, main vent bellows, and downcomer"Therefore, main vent intersection with the vent header, and tiebars are in accordance with 10 CFR 54.21 (c)(1)(ii) and 10 vent header miter joint, main vent bellows, and CFR 54.21 (c)(1)(iii)." downcomer and tiebars are in accordance with 10 CFR 54.21(c)(1)(ii)." Basis for Change: LRA Sections 4.6.2.1, 4.6.2.2, 4.6.2.3, and 4.6.2.5 LRA Sections 4.6.2.1, 4.6.2.2, 4.6.2.3, and 4.6.2.5 collectively cite a combination of 10 CFR 54.21(c)(1)(ii) and 10 CFR 54.21(c)(1)(iii) for the locations in this listing. Note -Any change in wording may also affect wording in Sections 4.6.2.2 and 4.6.2.4.55 A-il Commitment Number 23 states, in part: Revise to read: "Enhance the Reactor Vessel Sun,'eillance Program to add that if the CNS standby capsule is removed fom the reactor"Enhance the Reactor Vessel Surveillance Program to vessel without the intent to test it, the capsule will be stored in a add that if the CNS standby capsule is removed from the manner which maintains it in a condition which would permit its reactor vessel without the intent to test it, the capsule future use, including dur.ing the period cf extended operation.

will be stored in a manner which maintains it in a condition which would permit its future use, including Enhance the program to ensure that the additional requirements that during the period of extended operation." are specified in the final NRC safety evaluation for BWRVIP-1 16 will be addressed before the period of extended operation." CNS does not have a standby capsule. Moreover, the third License Condition described in Section 1.7 Basis for Change: License Condition 3 subsumes the need to make subsumes the need to make this commitment should this commitment.

NLS2010051 Attachment 1 Page 18 of 18 Comment Page Number! Comment Suggested Resolution Number Section Number NPPD acquire offe in the future. Accordingly, it is being deleted (see Attachment 2, LRA Changes 1 and 2).