ML24137A094
| ML24137A094 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/17/2024 |
| From: | Byrd T NRC/NRR/DORL/LPL4 |
| To: | Dent J Nebraska Public Power District (NPPD) |
| Byrd T, NRR/DORL/LPL4 | |
| References | |
| EPID L-2024-LLA-0015 | |
| Download: ML24137A094 (1) | |
Text
May 17, 2024 John Dent, Jr.
Executive Vice President and Chief Nuclear Officer Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue P.O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - REGULATORY AUDIT PLAN IN SUPPORT OF LICENSE AMENDMENT REQUEST TO MODIFY ALLOWABLE VALUE REGARDING TECHNICAL SPECIFICATION FOR HIGH PRESSURE COOLANT INJECTION PUMP DISCHARGE LOW FLOW (EPID L-2024-LLA-0015)
Dear John Dent:
By letter dated February 16, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24047A273), Nebraska Public Power District (the licensee) submitted a license amendment request (LAR) for Cooper Nuclear Station (Cooper), requesting to modify Technical Specification (TS) table 3.3.5.1-1, Emergency Core Cooling System Instrumentation; Function 3.f, High Pressure Coolant Injection Pump Discharge Flow - Low (Bypass), from greater than or equal to 490 gallons per minute to greater than or equal to 523 gpm.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensees application and determined that a regulatory audit will assist in the timely completion of the review. The NRC staff will conduct a regulatory audit to support its review in accordance with the enclosed audit plan. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information.
The NRC staff will conduct the audit to increase its understanding of the application and identify information that will require docketing to support the NRC staffs regulatory findings. The NRC staff will conduct the audit virtually as soon as the portal can be established through July 31, 2024.
J. Dent, Jr.
If you have any questions, please contact me at 301-415-3719 or by email to Thomas.Byrd@nrc.gov.
Sincerely,
/RA/
Thomas J. Byrd, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Audit Plan cc: Listserv
Enclosure REGULATORY AUDIT PLAN IN SUPPORT OF LICENSE AMENDMENT REQUEST REGARDING MODIFICATION OF TECHNICAL SPECIFICATION FOR HIGH PRESSURE COOLANT INJECTION PUMP LOW FLOW VALUE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 BACKGROUND
By letter dated February 16, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24047A273), Nebraska Public Power District (NPPD, the licensee) submitted a license amendment request (LAR) for Cooper Nuclear Station (Cooper or CNS),
requesting to modify Technical Specification (TS) Table 3.3.5.1-1 Emergency Core Cooling System Instrumentation; Function 3.f, High Pressure Coolant Injection [HPCI] Pump Discharge Flow - Low (Bypass), from greater than or equal to 490 gallons per minute to greater than or equal to 523 gpm.
The U.S. Nuclear Regulatory Commission (NRC) staff from the Office of Nuclear Reactor Regulation (NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures, Revision 6, dated July 31, 2020 (ML19248C539).
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information identified during the audit that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 31, 2019 (ML19226A274), with exceptions noted within this audit plan.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The NRC staffs objectives of the audit are the following:
Obtain information to support requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information, dated August 5, 2021 (ML21141A238).
Clarify calculated values used to validate the new values submitted by the licensee.
Understand terminology differences between setpoint methodology NEDC-31366P-A (General Electric Redbook) and CNS Engineering Procedure 3.26.3 (e.g., setpoint margin (SM).
Validate the use of %span and %reading within calculation.
Verify new barton gage accuracy was considered when calculating the new as-left tolerance value proposed in the submittal.
Verify that the elevation correction not required in calculation.
Validate assumption 23.
Verify three setpoint values shown in section 5, Conclusions, of the enclosure to the LAR, Calculation NEDC92-050AA, Revision 6, HPCI-FIS-78 (Switches 1 & 2) Setpoint Calculation, and how each setpoint is used.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff requests that the licensee have the information in the attached initial audit list readily available and accessible for the NRC staffs review via an internet-based portal. The staff may request additional documents to be added to the portal over the course of the audit. The staff requests for additions shall be made, as needed, to the DORL project manager, who will provide the requests to the licensee.
Based on the review of the documents listed below, the NRC staff will determine whether it needs to request any additional documents to be made available on the portal or whether additional information needs to be submitted on the docket for the staff to complete the review of the requested changes.
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff from NRR:
Thomas Byrd, Plant Licensing Branch IV (LPL4)
Joseph Ashcraft, Instrumentation and Controls Branch (EICB)
Matthew Hamm, Technical Specifications Branch (STSB)
Summer Sun, Nuclear Systems Performance Branch (SNSB) 6.0 LOGISTICS The audit will be conducted virtually as soon as an online portal (also known as electronic portal, ePortal, or electronic reading room) can be established by the licensee through July 31, 2024.
If requested, the audit team will conduct a telephone conference with the licensee for the purposes of introducing the team, discussing the scope of the audit, and describing the information to be made available on the internet portal. The audit team will also confirm with the licensee if the information made available on the online portal contains any sensitive or proprietary information. The audit team expects to request that representatives of NPPD answer audit team questions during the audit related to information provided on the portal at a mutually agreeable day and time by telephone conference. An exit meeting/call will be held at the conclusion of the audit.
The NRC staff requests the licensee to have the information referenced in the attached table below of this audit plan available and accessible for the NRC staffs review via an internet-based portal within 2 weeks of the date of this audit plan. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal. The NRC staff requests the licensee to notify the review team when an audit item is added to its portal by sending an email to the NRC licensing project manager.
The NRC staff does not foresee the need for an onsite visit or in-person discussions between the NRC and licensee staff to discuss information to be provided on the portal at this time.
However, if the need for a such a meeting is identified in the future, the audit plan will be revised, and the schedule for the audit will be adjusted accordingly. The NRC licensing project manager will coordinate any changes to the audit schedule and location with the licensee.
7.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through a web-based portal that allows the NRC staff to access documents over the internet. The following conditions associated with the online portal must be maintained while the NRC staff have access to the online portal:
The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff participating in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password information should be provided directly to members of the NRC staff as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff participating in the audit. All other communications should be coordinated through the NRC licensing project manager.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, in accordance with NRR Office Instruction LIC-115 and will issue such RAIs separately from audit-related correspondence. The NRC staff will prepare and issue an audit summary report prior to completing its review of the LAR.
Attachment:
Initial Audit Items List
Attachment Initial Audit Items List Item No.
Audit Item 1
NEDC 11-045, Revision 0, Instrument Drift Analysis for Barton 289A and 581 A Differential Pressure (DP) Switches (Range 0 to 10 in WC) (Reference 49 of Calculation 3-EN-DC-126).
2 CNS [Cooper Nuclear Station] Engineering Procedure 3.26.3, Rev. 9, Instrument Setpoint and Channel Error Calculation Methodology (Reference 6 of Calculation 3-EN-DC-126).
3 CNS Surveillance Procedure 6.HPCI.312, Rev 14, HPCI [High Pressure Coolant Injection] Pump Low Discharge Flow Channel Calibration (Reference 7 of Calculation 3-EN-DC-126).
4 EQDP.2.112 Rev. 8, Barton Model 581A-0 Differential Pressure Indicating Switch (Ref 46 of Calculation 3-EN-DC-126).
5 Vendor Manual 0773 Rev 13, Barton Differential Pressure Indicating Switches, Model 580A-0 & 581 A-0 (Reference 47 of Calculation 3-EN-DC-126).
6 DI 2544, ITT Barton Qualification Test Report No. R3-580A-29 for ITT Barton Models 580A, 581A, and 583A Mild Environment Differential Pressure Switch Instruments, dated 2/23/87 (Reference 48 of Calculation 3-EN-DC-126).
- By email NRR-106 OFFICE NRR/DORL/LPL4/PM*
NRR/DORL/LPL4/LA*
NRR/DSS/STSB/BC*
NRR/DEX/EICB/BC*
NAME TByrd PBlechman SMehta FSacko DATE 5/10/2024 5/16/2024 5/10/2024 5/10/2024 OFFICE NRR/DSS/SNSB/BC*
NRR/DEX/EEEB/BC*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME PSahd WMorton JRankin TByrd DATE 5/10/2024 5/10/2024 5/16/2024 5/17/2024