ML24032A238

NRR E-mail Capture - Cooper Nuclear Station - LAR Dfo Tank Inspection RAI Issuance

ML24032A238
Person / Time
Site:	Cooper
Issue date:	02/01/2024
From:	Byrd T NRC/NRR/DORL/LPL4
To:	Dewhirst L Nebraska Public Power District (NPPD)
Byrd T
References
L-2023-LLA-0126
Download: ML24032A238 (5)

Text

From:

Thomas Byrd Sent:

Thursday, February 1, 2024 1:30 PM To:

Dewhirst, Linda R.; Unruh, Mark E.

Cc:

Van Der Kamp, David W.

Subject:

RE: RE: RE: Cooper - RAI - LAR DFO Tank Inspections (EPID L-2023-LLA-0126)

Attachments:

RAI-10129-R1-FINAL DFO Tank Inspections Revised (EPID L-2023-LLA-0126).pdf On January 25, 2024, the U.S. Nuclear Regulatory Commission (NRC) Staff sent Nebraska Public Power District (the licensee) the draft Request for Additional Information (RAI) identified below. This RAI relates to the license amendment request dated September 26, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23249A134), seeking to add a note to technical specifications (TS) Section 3.8.3 in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90. This RAI also supersedes the previously issued RAI (ML24010A090). The proposed amendment would allow the use of temporary storage tanks utilized to supplement the required fuel oil storage tank inventory used by the emergency diesel generators. The proposed TS 3.8.3 change would only be applicable to the 2024 Refueling Outage 33 while in Modes 4 or 5 to allow cleaning, inspection, and repairs to the permanent diesel fuel oil storage tanks.

The licensee subsequently informed the NRC staff that further clarification was needed, the items were discussed January 31, 2024, and subsequently understood. A publicly available version of this final RAI (attached with Draft removed) will be placed in the NRCs ADAMS system. As agreed, please provide a response to this RAI within 30 days of this correspondence or by March 13, 2024.

Thomas Byrd Project Manager - Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Office: (301) 415-3719 From: Thomas Byrd <Thomas.Byrd@nrc.gov>

Sent: Thursday, January 25, 2024 1:23 PM To: Dewhirst, Linda R. <lrdewhi@nppd.com>

Cc: Unruh, Mark E. <m1unruh@nppd.com>; Van Der Kamp, David W. <dwvande@nppd.com>

Subject:

Cooper - RAI - LAR DFO Tank Inspections (EPID L-2023-LLA-0126)

EXTERNAL: This email originated from OUTSIDE of NPPD! Do not click links, open attachments, or reply, unless you recognize the sender's email address and know the contents are safe! This email is from prvs=747d304a4=thomas.byrd@nrc.gov.

By letter dated September 26, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23249A134), Nebraska Public Power District (NPPD, the licensee) submitted a license amendment request (LAR) for Cooper Nuclear Station (Cooper), seeking to add a note to technical specifications (TS) Section 3.8.3 in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90. The proposed amendment would allow the use of temporary storage tanks utilized to supplement the required fuel oil storage tank inventory used by the emergency diesel generators. The proposed TS 3.8.3 change would only be applicable to the 2024 Refueling Outage 33 while in Modes 4 or 5 to allow cleaning, inspection, and repairs to the permanent diesel fuel oil storage tanks.

The Nuclear Regulatory Commission (NRC) staff reviewed the submittal and determined that additional information, as described in the attached request for additional information (RAI), is required for the staff to complete its review of the application. This RAI is a revised copy of the initial RAI and identified as a draft at this time to confirm your understanding of the information that the NRC staff needs to complete the evaluation. Please let me know if you would like to have a call with the NRC staff to clarify this request. If the request for information is understood, please respond to this RAI within 30 days of the date of this request.

Thomas Byrd Project Manager - Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Office: (301) 415-3719

Hearing Identifier:

NRR_DRMA Email Number:

2385 Mail Envelope Properties (BLAPR09MB6339DE51566BB5F23A865FEDFA432)

Subject:

RE RE RE Cooper - RAI - LAR DFO Tank Inspections (EPID L-2023-LLA-0126)

Sent Date:

2/1/2024 1:29:58 PM Received Date:

2/1/2024 1:29:00 PM From:

Thomas Byrd Created By:

Thomas.Byrd@nrc.gov Recipients:

"Van Der Kamp, David W." <dwvande@nppd.com>

Tracking Status: None "Dewhirst, Linda R." <lrdewhi@nppd.com>

Tracking Status: None "Unruh, Mark E." <m1unruh@nppd.com>

Tracking Status: None Post Office:

BLAPR09MB6339.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 3900 2/1/2024 1:29:00 PM RAI-10129-R1-FINAL DFO Tank Inspections Revised (EPID L-2023-LLA-0126).pdf 147291 Options Priority:

Normal Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

1 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION COOPER - LAR TO PERFORM DFO TANK INSPECTIONS NEBRASKA PUBLIC POWER DISTRICT COOPER, UNIT 1 DOCKET NO. 05000298 ISSUE DATE: 01/25/2024

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Background===

By letter dated September 6, 2023, the Nebraska Public Power District (NPPD) submitted a license amendment request (LAR) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23249A134) to revise Technical Specifications (TS) 3.8.3, Diesel Fuel Oil (DFO), Lube Oil, and Starting Air, to allow for the use of temporary fuel oil storage tanks to supplement the required fuel oil storage inventory used by the emergency diesel generators during performance of required DFO tank inspections. This TS change would be applicable during the 2024 Refueling Outage 33 while in Modes 3 and 4 to allow cleaning, inspection, and any needed repairs, of the permanent DFO storage tanks.

Regulatory Basis The regulation at Title 10 of the Code of Federal Regulations (CFR) 50.36(c)(2)(i) requires that technical specifications (TS) contain limiting conditions for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.

The regulation at 10 CFR 50.36(c)(3), Surveillance requirements, states, [s]urveillance requirements [SRs] are requirements related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Cooper Updated Safety Analysis Report (USAR) section 5.2 states, in part, [e]ach [diesel generator] unit shall have a unit fuel (day) tank. Either unit fuel (day) tank shall be supplied from the combined two main fuel storage tanks Both main fuel oil tanks combined shall have sufficient fuel for seven days of operation of one DG unit at full load which bounds postulated accident conditions.

USAR section 5.4.1 states, in part, [e]ither DG is capable of starting and continuously operating under postulated accident conditions for a period of seven days using fuel stored on-site in underground storage tanks.

USAR Appendix F, lists Coopers conformance to the July 1967 Atomic Energy Commission's draft general design criteria (GDCs). Section 2.1.2 of Appendix F, Criterion 2 -- Performance Standards, states, in part:

Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences

2 shall be designed, fabricated, and erected to performance standards that will enable the facility to withstand, without loss of the capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornadoes, flooding conditions, winds, ice, and other local site effects. The design bases so established shall reflect: (a) appropriate consideration of the most severe of these natural phenomena that have been recorded for the site and the surrounding area and (b) an appropriate margin for withstanding forces greater than those recorded to reflect uncertainties about the historical data and their suitability as a basis for design.

Note: These questions supersede the previously issued RAI, dated January 4, 2024 (ML24010A117), for the review of license amendment request (LAR) dated September 6, 2023 (ML23249A134).

Question 1 In attachment 3 to the LAR, the licensee provided a markup of a proposed one-time change to Cooper TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, to support a temporary configuration during diesel fuel oil storage tank maintenance activities. Proposed Note 2 to the TS 3.8.3 actions table would state:

A combination of fuel oil volumes in temporary storage tanks and permanent storage tanks may be utilized to support OPERABILITY of a DG [diesel generator] during tank cleaning and inspection maintenance activities. Equipment (temporary transfer pump, hoses, and appropriate fittings) capable of supplying fuel oil to the in-service permanent tank aligned to the operable DG must be available. The fuel oil in the temporary tanks, in conjunction with the fuel oil in the permanent tanks, must be within the limits of Condition A and Condition C. This temporary note is applicable only to the DG aligned to the in-service permanent tank. This temporary note is applicable only during Refuel Outage 33 while in MODES 4 or 5. This allowance is contingent upon meeting the compensatory measures contained in Attachment 2 of Nebraska Public Power District letter NLS2023029.

In the NRC staffs assessment, the note assumes that the temporary configuration meets the LCO 3.8.3 requirements for operability. However, to meet the diesel fuel oil requirements for a seven-day supply in SR 3.8.3.1 and subsequently LCO 3.8.3, the location of the diesel fuel oil is specified as the two main underground tanks described in the Cooper USAR sections 5.2 and 5.4.1. This implies that, in the temporary configuration, the LCO would not be met and TS 3.8.3 condition A entry would apply.

TS 3.8.3 condition A is applicable when the diesel fuel oil contained in the storage tanks is less than a seven-day supply and greater than a six-day supply. The required action is to, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, restore the fuel oil level within limits. This limit for the combined volume in the two storage tanks is at least a seven-day supply of diesel fuel oil (i.e., as specified in SR 3.8.3.1.)

Please respond to the following:

a. Provide further justification for the proposed notes current location and wording or consider relocating the proposed note to a TS 3.8.3 action statement and revising it to include an extended completion time for the temporary configuration.

b. The third sentence in the proposed TS note states: The fuel oil in the temporary tanks, in conjunction with the fuel oil in the permanent tanks, must be within the limits of Condition A and

3 Condition C. This sentence appears in conflict with item 9 of Technical Specifications Compensatory Measures found in attachment 2 to the LAR, which would require verification of at least a seven-day supply of fuel oil every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Note 2 appears to require only a six-to seven-day supply (TS 3.8.3 condition A) and it also appears to prevent entry into conditions A and C (fuel oil particulates not within limit) during the fuel oil storage tank maintenance activity.

Discuss the purpose of the third sentence in the note or provide a revision to the note or the LAR.

Question 2 GDC 2 requires the licensee to protect structures, systems, and components (SSCs) from external hazards. With the use of unprotected temporary equipment, the licensee must evaluate the potential impact of external hazards and details associated with use of unprotected SSCs.

Section 3.6 of LAR attachment 1 indicates, in part, Actions will be taken to secure the fuel transfer equipment filter/pump systems, hoses, etc., in the event of severe weather. Provide discussion of actions that will be taken to secure unprotected equipment and methods used to avoid introducing potential missiles which could adversely impact safety-related SSCs.

OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/BC NRR/DSS/STSB/BC NAME TByrd JRankin SMehta DATE 01/25/2024 01/25/2024 01/23/2024