ML20237C744

Informs That NRC Staff Performed Initial Review of 980806 Request for Review & Approval of Proposed License Amend & Determines That Amend Request Need Not Be Treated on Exigent Basis

ML20237C744
Person / Time
Site:	Cooper
Issue date:	08/19/1998
From:	Hall J NRC (Affiliation Not Assigned)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
References
GL-91-18, TAC-MA2464, NUDOCS 9808240104
Download: ML20237C744 (4)

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UNITED STATES A

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30086 4001 (

.- ppkW August 19, 1998 Mr. G. R. Hom l Sr. Vice President of Energy Supply Nebraska Public Power District 141415th Street Columbus, NE 68601

SUBJECT:

REQUEST FOR EXIGENT LICENSE AMENDMENT RELATED TO SECONDARY CONTAINMENT ISOLATION - COOPER NUCLEAR STATION (TAC NO. MA2464)

Dear Mr. Hom:

By letter dated August 6,1998, the Nebraska Public Power District (the District) requested NRC

. review and approval of a proposed license amendment for the Cooper Nuclear Station (CNS) to accept the as-built configuration of the Secondary Containment and Reactor Building Isolation

- and Control System. Although your request does not involve any changes to the CNS license or technical specifications, you determined that an Unreviewed Safety Question (USQ) exists, which required you to submit an application for an amendment to the license, as specified in )

10 CFR 50.59(c). You also requested NRC review and approval of the proposed amendment on an exigent basis, as discussed below.

In your application, you stated thct the current Updated Safety Analysis Report (USAR) is confusing, in that it indicates that the postulated Refueling Accident results in limited fission i product releases through the normal reactor building ventilation exhaust path, and in other sections, also indicates that no releases would occur. You determined that the original analysis for this scenario assumed that no direct releases from the reactor building would occur, due to the fast closure of the reactor building ventilation exhaust isolation dampers. The as-built . ,

design of the plant consists of two trains of the reactor building normal ventilation exhaust, with I

. an inboard air-operated isolation damper and outboard motor-operated isolation damper in

. each train. Due to the fact that the outboard dampers are slower closing (up to 90 seconds, versus 12 seconds for the inboard dampers), and accounting for a single failure of an inboard i damper, you performed revised offsite doses calculations associated with a fuel handling accident, which resulted in slightly higher doses for the refueling accident scenario. Based on 3 the slight increase in dose consequences for this previously analyzed accident, you concluded that a USQ existed, and that NRC review and approval in the form of a license amendment was needed, in order to reconcile the USAR inconsistencies.

L in your application, you further requested that the NRC review and approve the proposed amendment on an exigent basis, based on your determination that the subject amendment request requires approval prior to the unrestricted movement of fuel. As a result of this l determination, you have restricted the movement of fuel and heavy loads over irradiated fuel.

You stated that the Fall 1998 refueling outage is currently scheduled to commence on

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Mr. G. R. Horn .

October 2,1998, and that receipt of new fuel is expected in mid-August; thus the current restrictions will prevent the inspection and staging of the new fuel and impact the start of the refueling outage, unless the amendment is approved promptly.

The NRC staff has performed an initial review of your application, and has determined that the amendment request need not be treated on an exigent basis. NRC GL 91-18, Revision 1, dated October 8,1997, states that the need to obtain NRC approval for the final resolution of a degraded or nonconforming condition does not affect the licensee's authority to continue operation (or restart from a shutdown), provided that necessary equipment is operable and the degraded or nonconforming equipment is not in conflict with any technical specification.

Section 2.4 of GL 91-18, Revision 1 defines a nonconforming condition to include as-built equipment that does not meet FSAR descriptions. In accordance with the GL, ycu have initiated appropriate corrective action in applying for a license amendment, so that the USAR can be revised to reflect the as-built plant. You have determined that the as-built configuration J

is acceptable, and that the slightly higher offsite doses resulting from the revised assumptions used in the dose calculations are still a small fraction of 10 CFR Part 100 limits. As ststed in the GL, the proposed final resolution for such a situation can be under staff review and not affect the continued operation of the plant, because interim operation is governed by the processes of operability determination and corr:.ctive action of 10 CFR Part 50, Appendix B.

On this basis, the staff does not believe that the current restrictions on fuel handling activities imposed by the District are necessary, and therefore, the staff will review the amendment request in accordance with its normal procedures.

Please contact me at (301) 415-1336 if you have any questions on this issue. j Sincerely, ORIGINAL SIGNED BY: D. Wigginton for James R. Hall, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects ill/IV Office of Nuclear Reactor Regulation Docket No. 50-298 cc: See next page DISTRIBUTION:

(Docket Fuef PUBLIC PD4-1 r/f EMcKenna CHawes ACRS OGC (15B18) TGwynn, RIV JHall EAdensam (EGA1) JHannon CMiller REmch Document Name: COOA2464.LTR l OFC RMll?p4-1 LA/PD4-1 P D V-1 NAME Mb CHaNs JHannon DATE I/ d/98  ? /$ /98 h/98 COPY h/NO YES/NO / IYEhO OFFfefA' L RECORD COPY

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• d Mr. G. R. Horn - October 2,1998, and that receipt of new fuel is expected in mid-August; thus the current restrictions will prevent the inspection and staging of the new fuel and impact the start of the refueling outage, unless the amendment is approved promptly.

The NRC staff has performed an initial review of your application, and has datermined that the amendment request need nct be treated on an exigent basis. NRC Generic Letter (GL) 91-18, Revision 1, dated October 8,1997, states that the need to obtain NRC approval for the final resolution of a degraded or nonconforming condition does not affect the licensee's authority to continue operation (or restart from a shutdown), provided that necessary equipment is operable and the degraded or nonconforming equipment is not in conflict with any technical specification.

Section 2.4 of GL 91-18, Revision i defines a nonconforming condition to include as-built equipment that does not meet FSAR descriptions. In accordance with the GL, you have initiated appropriate corrective action in applying for a license amendment, so that the USAR can be revised to reflect the as-built plant. You have determined that the as-built configuration is acceptable, and that the slightly higher offsite doses resulting from the revised assumptions used in the dose calculations are still a small fraction of 10 CFR Part 100 limits. As stated in the GL, the proposed final resolution for such a situation can be under staff review and not I affect the conthued operation of the plant, because interim operation is govemed by the processes of operability determination and corrective action of 10 CFR Part 50, Appendix B.

On this basis, the staff does not believe that the current restrictions on fuel handling activities imposed by the District are necessary, and therefore, the staff will review the amendment request in accordance with its normal procedures.

Please contact me at (301) 415-1336 if you have any questions on this issue.

Sincerely,

/

James R. Hall, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/lV Office of Nuclear Reactor Regulation Docket No. 50-298 -

cc: See next page l

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Mr. G. R. Horn j Nebraska Public Power District Cooper Nuclear Station  !

cc: I l'

Mr. John R McPhail, General Counsel Lincoln Electric System Nebraska Public Power District ATTN: Mr. Ron Stoddard  ;

P. O. Box 499 1040 O Street l

Columbus, NE 68602-0499 Box 80869  !

Lincoln, NE 68501 i Nebraska Public Power District I

ATTN: Mr. J. H. Swailes MidAmerican Energy Vice President of Nuclear Energy ATTN: Dr. William D. Leech, Manager-Nuclear ]

j P. O. Box 98 907 Walnut Street Brownville, NE 68321 {

P. O. Box 657 Des Moines, IA 50303-0657 j

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Randolph Wood, Director Nebraska Department of Environmental l Nebraska Public Power District {

Control ATTN: Mr. B. L. Houston, Nuclear i P. O. Box 98922 Licensing & Safety Manager Lincoln, NE 68509-8922  !

P. O. Box 90 1 Brownville, NE 68321 Mr. Larry Bohlken, Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Aubum, NE 68305 Senior Resident inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington,TX 76011 Ms. Cheryl Rogers, LLRW Program Manager Division of Radiological Health Nebraska Department of Health 301 Centennial Mall, South l P. O. Box 95007 Lincoln, NE 68509-5007 f

f' Mr. Ronald A. Kucera, Department Director of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 {

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