NLS2002085, Nebraska Public Power District Safety Evaluation for Appendix R to 10 CFR Part 50, Items II.G.3 and Iii.I, Alternate or Dedicated Shutdown Capability Clarification

Nebraska Public Power District Safety Evaluation for Appendix R to 10 CFR Part 50, Items II.G.3 and Iii.I, Alternate or Dedicated Shutdown Capability Clarification

ML022140430
Person / Time
Site:	Cooper
Issue date:	07/29/2002
From:	Coyle M Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2002085
Download: ML022140430 (3)

Text

N Nebraska Public Power District Nebraska's Energy Leader NLS2002085 July 29, 2002 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Safety Evaluation For Appendix R to 10 CFR Part 50, Items II.G.3 and III.L, Alternate or Dedicated Shutdown Capability Clarification

References:

I. NRC Letter, "Safety Evaluation for Appendix R to 10 CFR Part 50, Items II.G.3 and III.L, Alternate or Dedicated Shutdown Capability,"

from Domenic B. Vassallo to J. M. Pilant (NPPD) dated April 16, 1984.

2. NPPD Letter LQA8300256, "Response to IOCFR50, Appendix R,

'Fire Protection of Safe Shutdown Capability- Volume IlI,"' from J.M. Pilant (NPPD) to D.B. Vassallo dated December 2, 1983.

The Nuclear Regulatory Commission (NRC) issued to Nebraska Public Power District (NPPD) its review of the Cooper Nuclear Station (CNS) Response to IOCFR50, Appendix R, "Fire Protection of Safe Shutdown Capability- Volume III," in Reference

1. The accompanying safety evaluation (SE) concluded that CNS meets the requirements of Appendix R,Section III.G.3 and IlI.L and stated that the NRC considered the issue resolved for our facility. NPPD agrees with the overall conclusion. However, during a recent review of plant procedures, differences were identified between the content of some post-fire procedures and two statements in the SE enclosed with Reference I.

Further review identified differences between statements in the submittal, Reference 2, and the SE. The differences dealt with whether repairs are necessary to achieve cold shutdown in two possible fire scenarios. Finding these differences identified the need for certain clarifications that are appropriate to make with respect to post-fire shutdown capability of CNS.

Clarifications The introduction to the SE states, "No repairs or modifications are required to effect hot or cold shutdown utilizing the alternate shutdown methods." Later in a section entitled "Repairs/72 Hour Requirement" the SE states, "The alternate shutdown methods have the capability of achieving cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after a fire event with no repairs."

As a clarification to these statements it should be noted that NPPD identified, in Reference 2 on page 4-19, two fire scenarios in which repairs might be needed in order to achieve and maintain cold shutdown. These two events being first, a single fire event Cooper Nuclear Station #6, _

P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 http://www nppd.com

NLS2002085 Page 2 of 2 could possibly damage the power supply cables to both diesel generator fuel oil transfer pumps, and second, a single fire event could possibly damage the power supply cables to both station battery chargers. In either of these cases repairs would be needed in order to achieve and maintain cold shutdown. The specific reference on page 4-19 is "If both fuel oil transfer pumps have been damaged, then a repair procedure will be initiated to regain their operation and replenish the day tanks.....The redundant power cables to both the station battery chargers could be damaged by a severe fire in the vicinity of the Auxiliary Relay Room. To compensate for the loss of charging capability to both of the 125V dc batteries and/or both the 250V dc batteries a post-fire repair capability will be established." Repairs are allowed by 10 CFR 50 Appendix R Section III.L.5 to achieve and maintain cold shutdown.

The above clarification is offered as such and does not impact the NRC's conclusion that Cooper Nuclear Station meets the requirements of Appendix R,Section III.G.3 and III.L.

Should you have any questions concerning this matter, please contact Paul Fleming at (402) 825-2774.

Sincerely, Site Vice President

/cb cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV- 1 Senior Resident Inspector USNRC NPG Distribution Records

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS Correspondence Number: NLS2002085 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE None 1-1-

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