ML24227A082
| ML24227A082 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/03/2024 |
| From: | Byrd T Plant Licensing Branch IV |
| To: | Dent J Nebraska Public Power District (NPPD) |
| Wengert T, NRR/DORL/LPLIV, 415-4037 | |
| References | |
| EPID L-2024-LLA-0015 | |
| Download: ML24227A082 (7) | |
Text
September 3, 2024 John Dent, Jr.
Executive Vice President and Chief Nuclear Officer Nebraska Public Power District 72676 648A Avenue P.O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION -
SUMMARY
OF REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUEST TO MODIFY HIGH PRESSURE COOLANT INJECTION LOW FLOW VALUE (EPID L-2024-LLA-0015)
Dear John Dent:
By letter dated February 16, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24047A273), as supplemented by letter dated July 24, 2024 (ML24207A107), Nebraska Public Power District (the licensee) submitted a license amendment request (LAR) for the Cooper Nuclear Station (Cooper). The proposed amendment would revise the allowable value for Cooper Technical Specification 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation, 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 (gpm) to 523 gpm. The proposed change to the technical specification table is due to a planned replacement of the flow-indicating switch with a different model.
To support its review of the LAR, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a virtual regulatory audit via the use of an internet-based portal set up by the licensee from May 17, 2024, through August 6, 2024. During the regulatory audit, the NRC staff reviewed documents and held discussions with the licensees staff and its representatives. The regulatory audit summary is enclosed with this letter.
J. Dent, Jr.
If you have any questions, please contact me at 301-415-3719 or by email at 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:
Regulatory Audit Summary cc: Listserv
Enclosure REGULATORY AUDIT
SUMMARY
IN SUPPORT OF LICENSE AMENDMENT REQUEST TO MODIFY THE HIGH PRESSURE COOLANT INJECTION 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), as supplemented by letter dated July 24, 2024 (ML24207A107), Nebraska Public Power District (the licensee) submitted a license amendment request (LAR) for the Cooper Nuclear Station (Cooper). The proposed amendment would revise the allowable value for Cooper Technical Specification (TS) 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation, 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 (gpm) to 523 gpm. The proposed change to the TS is due to a planned replacement of the flow-indicating switch with a different model.
Information that the U.S. Nuclear Regulatory (NRC) staff relies upon to make the safety determination must be submitted on the docket. However, the NRC staff may review supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.71, Maintenance of records, and/or 10 CFR 54.37, Additional records and recordkeeping requirements, which, although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensees submitted information. To support its review of the LAR, the NRC staff issued a regulatory audit plan on May 17, 2024 (ML24137A094). The purpose of the audit is to review the documentation related to the subject of its application (e.g., calculations and reports) that were not submitted on the Cooper docket, to acquire additional understanding about the LAR, and to determine whether additional information is needed to be docketed to complete the NRC staffs safety evaluation.
2.0 AUDIT ACTIVITIES The NRC audit team consisted of NRC staff. Attachment 1 of this audit summary lists the individuals that took part in or attended the audit. The virtual regulatory audit was conducted from May 17, 2024, through August 6, 2024. Throughout the audit period, the NRC audit team used an internet-based portal provided by the licensee to review primarily non-docketed information related to the application. A formal, virtual audit meeting with the licensee was held on June 26, 2024, to facilitate technical discussions of audit questions and disciplines according to the audit plan.
Technical discussions were focused on details associated with the high pressure coolant injection (HPCI) low flow switch replacement plans and calculations associated with the HPCI low flow value change in the TS. On June 26, 2024, the NRC staff provided a brief conclusion of the formal virtual audit meeting, including audit objectives that were met and details on the path forward. Non-docketed information provided by the licensee in response to audit questions and the formal meeting is listed in attachment 2 of this audit summary. The licensee provided a supplemental response on July 24, 2024 (ML24207A107), providing details on changes in the calculations discussed during the regulatory audit. An audit closeout meeting was held on August 6, 2024.
3.0 RESULTS OF THE AUDIT In response to NRC staff questions discussed during the audit, the licensee provided a supplement on July 24, 2024 (ML24207A107).
Attachments:
- 1. List of Participants
- 2. List of Documents Reviewed During Audit List of Participants U.S. Nuclear Regulatory Commission Audit Team Name, Organization Thomas Byrd, NRR1/DORL2/LPL43 Joseph Ashcraft, NRR/DEX4/EICB5 Summer Sun, NRR/DSS6/SNSB7 Matthew Hamm, NRR/DSS/STSB8 Nebraska Public Power District (NPPD) Audit Team Name, Organization Linda Dewhirst, NPPD Regulatory Affairs Manager Dave Van Der Kamp, NPPD Licensing Technical Assistant Alan Able, NPPD I&C9 Design Engineer Supervisor Ryan Durr, NPPD I&C Design Engineer 1 Office of Nuclear Reactor Regulation (NRR) 2 Division of Operating Reactor Licensing (DORL) 3 Plant Licensing Branch IV (LPL4) 4 Division of Engineering and External Hazards (DEX) 5 Instrumentation and Controls (I&C) Branch (EICB) 6 Division of Safety Systems (DSS) 7 Nuclear Systems Performance Branch (SNSB) 8 Technical Specifications Branch (STSB) 9 Instrumentation and Controls (I&C)
List of Documents Reviewed During Audit Nebraska Public Power District (the licensee) provided an extensive list of supporting documents (e.g., calculations, reports, drawings, and procedures) on the Cooper Nuclear Station document portal available during the audit period. Below lists the documents available on the portal that the U.S. Nuclear Regulatory Commission audit team reviewed during the audit.
Calculation NEDC 11-045 Revision 0, Instrument Drift Analysis for Barton 289A and 581A Differential Pressure Switches Procedure 3.26.3 Revision 9, Instrument Setpoint and Channel Error Calculation Methodology Procedure 6.HPCI.312 Revision 14, HPCI [High Pressure Coolant Injection] Pump Low Discharge Flow Channel Calibration Environmental Qualification Data Package 2.112 Revision 8, Differential Pressure Indicating Switch, ITT Barton, 581A-0 Vendor Manual 0773 Revision 13, Differential Pressure Indicating Switches Models 580A-0 and 581A-0 Cameron Engineering Report No. 9ACR3-580A-29, Nuclear Qualification Test Report, Barton Models 580A, 581A and 583A Calculation NEDC 92-050AA Revision 7, HPCI-FIS-78 (Switches 1 & 2) Setpoint Calculation
- by email OFFICE NRR/DORL/LPL4/PM*
NRR/DORL/LPL4/LA*
NRR/DSS/STSB/BC*
NRR/DEX/EICB/BC*
NAME TByrd PBlechman SMehta(KWest for)
FSacko DATE 8/14/2024 8/15/2024 8/15/2024 9/3/2024 OFFICE NRR/DSS/SNSB/BC*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME PSahd JRankin TByrd DATE 8/15/2024 9/3/2024 9/3/2024