ML12012A154

Letter from NRC to Brian J. Ogady, Vice President - Nuclear and Chief Nuclear Officer, Nebraska Public Power-Cooper

ML12012A154
Person / Time
Site:	Cooper
Issue date:	05/06/2011
From:	Nick Taylor NRC Region 4
To:	O'Grady B Nebraska Public Power District (NPPD)
References
FOIA/PA-2011-0339, RIV-2011-A-0047
Download: ML12012A154 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV

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i 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125 May 6, 2011 Brian J. O'Grady, Vice President-Nuclear and Chief Nuclear Officer Nebraska Public Power - Cooper Nuclear Station 72676 648A Avenue Brownville, NE 68321

SUBJECT:

REQUEST FOR INFORMATION REFERENCE ALLEGATION RIV-201 1 -A-0047

Dear Mr. O'Grady:

The U.S. Nuclear Regulatory Commission (NRC) recently received information concerning activities at the Cooper Nuclear Station. We request that the Nebraska Public Power District evaluate the information described in the enclosure to this letter and submit the results of that evaluation to Region IV Office. If the Nebraska Public Power District determines a concern to be substantiated, please discuss the Nebraska Public Power District's consideration of appropriate root or apparent causes and generic implications of the substantiated concern and the appropriateness of corrective actions taken or planned.

Additionally, if your evaluation identifies any compliance issue with regard to NRC regulatory requirements or NRC commitments, please inform us regarding the requirement or commitrmfen, that was violated, the corrective actions taken or planned, and the corrective action documentation that addressed the issue. We ask that you reference our-tracking-number (RIV-201 1-A-0047) in your written response and also that you make any records of your evaluation available for possible NRC inspection.

The NRC will review your response to determine whether: (a) the individual conducting the investigation was independent of the organization with responsibility for the related functional area, (b) the evaluator was proficient in the related functional area, and (c) the evaluation was of sufficient depth and scope. Your response should describe how each of these attributes was satisfied. If individuals were interviewed as part of your review, your response should include the basis for determining that the number and cross section of individuals interviewed was appropriate to obtain the information necessary to fully evaluate the concerns, and the interview questions used.

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I Mr. Brian J. O'Grady RIV-201 1-A-0047 If your evaluation included a sample review of related documentation and/or potentially affected structures, systems, and components, your response should include the basis for determining that the selected sample size was appropriately representative and adequate to obtain the information necessary to fully evaluate the concerns. The NRC will consider these factors in reviewing the adequacy of your evaluation of these issues.

Within 30 days of the date of this letter, submit in writing the results of that evaluation to Mr. Nick Taylor, Senior Allegation Coordinator, at the address listed in the header of this letter.

We request that your response include the details of your evaluation and findings related to the validity of the information provided. We request that your response only be sent to Mr. Taylor at the address listed in the header of this letter. No other copies should be sent to the NRC (i.e.,

your response should not be docketed or otherwise submitted to the NRC Document Control Desk). Any information submitted electronically to the NRC should be provided on a CD or DVD as externally provided thumb drives are prohibited from use on NRC computers. The use of any web-based document room must provide only general support documents to avoid the release of allegation information beyond a "need to know;" i.e. procedures, work orders, etc.

We also request that your response contain no personal privacy, proprietary, or safeguards information. If personal privacy or proprietary information is necessary to provide an acceptable response, please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information).

If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.22. Finally, if you choose to utilize a web-based document room to provide any supporting documents, please specify the web location, any specific access requirements, and folder title of where the documents may be retrieved. In the title, please include Mr. Nick Taylor's name and the date of this letter. Do not use the allegation number.

This letter and its enclosure should be controlled and distribution limited to personnel with a "need to know." The response requested by this letter and the accompanying enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L.96-511.

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Mr. Brian J. O'Grady RIV-201 1-A-0047 Lastly, please contact Mr. Thomas Farnholtz, Chief, Engineering Branch 1, at 817-860-8243 within 5 days to discuss your evaluation or investigation plan and how it will incorporate the request for information enclosed. Please provide any additional questions you may have at this time concerning this request.

Sincerely, Nicholas H. Taylor Senior Allegation Coordinator Docket:

50-298 License: DPR-46

Enclosure:

As stated

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H::-I'JISQQO4'E In addition to the response information requested in the cover letter, we ask that your response address or include the following:

Issue 1 For the emergency diesel generator fuel-oil tank and associated underground piping, maintenance has been inadequate to protect against flooding.

1. What is the configuration of underground piping of the emergency diesel generator fuel oil tank and transfer system from the fuel oil storage tank to the day tank? Please provide piping and instrumentation diagrams.

2.

How does Cooper Nuclear Station inspect for flaws in the diesel fuel oil underground piping?

3.

How is the emergency diesel generator underground piping system leakage test performed?

Please provide the procedure used to complete the test.

4. What standards (ASME, ANSI, B31.1 etc.) are used to perform the system leakage test for the diesel fuel oil underground piping?

5. What is the frequency of the system leakage tests? Please provide results of all tests that have occurred in the previous 10 years.

6. Has any maintenance, modification, or replacement of the underground portion of diesel fuel oil system occurred since initial operation of Cooper Nuclear Station? If so, please provide the history of maintenance detailing the nature of work completed.

Issue 2 For the station blackout battery, the coping time is not adequate.

1. What is the elevation of the station blackout batteries?

2. Can Cooper Nuclear Station shutdown and cool down the plant during station blackout coping timeframe? Please provide the station blackout coping analysis.

3. Does Cooper Nuclear Station have guidelines for connecting the severe accident diesel to the station blackout battery charger? If so, please provide those guidelines.

4. With the new or revised flood levels of the Missouri River, will this affect the movement of the severe accident diesel generator from its storage location to its specified location?

RIV-201 1-A-0047 Enclosure

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5. Please provide a map of the storage locations, installed position, and cable installation of the severe accident diesel and its connections.

6. When connecting the severe accident diesel generator to the battery chargers, what is the greatest distance that can be achieved by the cable?

Issue 3 For a flooding scenario, the planned compensatory measures and emergency operating procedures are inadequate

1. What are your plans to update flood protection and emergency operating procedures because of new information from the Upper Mississippi River System Flow Frequency Study published by the US Army Corps of Engineers in January 2004?

2. Please provide a copy of the new design basis flood analysis at Cooper Nuclear Station that was conducted as a product of new information in the Upper Mississippi River System Flow Frequency Study.

3. What changes were made to your existing emergency operating procedures when new flood information was received?

4. How does Cooper Nuclear Station protect the site, emergency diesel generators, and other nuclear safety related systems against the 100 year flood?

Issue 4 The Cooper Nuclear Station accident scenario response is not adequate.

1. In a flooding accident scenario, what is the control room response to ensure that the reactor is in a safe shutdown condition if the ultimate heat sink and diesel generators are lost in a flood event?

2. What are your procedures for use of the standby liquid control system in-loss-of-coolant accident, station blackout, and flood events? Please provide the procedures.

3. Please explain how and when the standby liquid control system is used during a loss-of-coolant accident, station blackout, and flood events. Please describe the basis for those plans.

4. Please provide the accident analyses for the use of the standby liquid control system and loss-of-coolant accident, station blackout, and flood accident scenarios.

RIV-201 1-A-0047 Enclosure

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5. What emergency, abnormal, or severe accident procedures and indications are used to ensure that operators would understand when to operate the standby liquid control system if conditions existed in a loss-of-coolant accident, station blackout, and flood scenario?

RIV-201 1-A-0047 Enclosure

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