NLS2015083, Rescission of License Renewal Commitment to Recoat the Torus
| ML15280A357 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/29/2015 |
| From: | Limpias O Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2015083 | |
| Download: ML15280A357 (3) | |
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Nebraska Public Power District NLS201 5083 Always there when you need us September 29, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Rescission of License Renewal Commitment to Recoat the Torus Cooper Nuclear Station; Docket No. 50-298, License No. DPR-46
Reference:
- 1. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S. Nuclear Regulatory Commission, dated May 4, 2010, "Response to Open Items from the Safety Evaluation Report and Request for Additional Information Related to the License Renewal of Cooper Nuclear Station" (NLS2010050)
- 2. NUREG-1944, "Safety Evaluation Report Related to the License Renewal of Cooper Nuclear Station," dated October 2010
Dear Sir or Madam:
The purpose of this letter is to notify the Nuclear Regulatory Commission (NRC) that Nebraska Public Power District (NPPD) has rescinded the License Renewal commitment to recoat the Cooper Nuclear Station (CNS) torus. This submittal is made pursuant to License Condition 2.F of the CNS renewed Operating License, which requires written NRC notification of the implementation of (and by inference the rescission of) License Renewal commitments.
In Reference 1, NPPD made the 'following commnitment:
NIPPD will recoat the wetted portion of the CNS torus within three years after entering the PEO. (Due Date: January 18, 2017) (Commitment NLS2010050-01)
This commitment was affirmed in Appendix A of Reference 2. After receipt of the renewed Operating License on November 29, 2010, NPPD commenced implementation activities for the new and enhanced Aging Management Programs. During this time, NPPD began reconsidering the prudency of recoating the torus from a technical perspective. An engineering study was commissioned for Structural Integrity Associates, Inc. to examine the general corrosion being experienced by the CNS torus. The study concluded that if maintenance (e.g., desludging, inspection, and coating repairs) is performed on a regular basis, and high water quality is maintained, the general corrosion of the torus carbon steel components will continue to be mitigated and the service life of the coating system will continue to ensure structural integrity during the period of extended operation, without recoating of the torus. It further concluded there is no technical justification for recoating the CNS torus. NPPD has formally credited these COOPE NUCLEA.STATION i
P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax:, (402) 825-5211 ww.nppd.corn
NLS20 15083 Page 2 of 2 additional activities in the Containment Inspection Program, and in the CNS Updated Safety Analysis Report.
This commitment rescission was made under the provisions of 10 CFR 50.59, as allowed by CNS License Condition 2.E (as modified by CNS License Amendment 247), which concluded that prior NRC approval was not required. Notwithstanding, this matter was discussed with the NRC Staff on June 17, 2015, prior to making the change effective. Conforming changes were made to two other License Renewal commitments related to the torus recoat under the provisions of 10 CFR 50.59, as follows:
NPPD will remove sludge and inspect the wetted portion of the torus every refueling outage from now until the torusis rcoatedend of the period of extended operation.
(Commitment NLS20 10050-02)
NIPPD will complete an analysis following each torus inspection that demonstrates that the projected pitting of the torus up to the next inspection intervaltime that the to...s is
.,ete,,*,.,,, will not result in reduction of torus wall thickness below minimum acceptable values. (Commitment NL52010050-03)
The modified commitments are contained in the attachment to this letter.
Should you have any questions concerning this matter, please contact Jim Shaw, CNS Licensing Manager, at (402) 825-2788.
Oscar-
. Limpias Vice President - Nulclear and Chief Nuclear Officer
/lb cc: Regional Administrator USNRC - Region IV Cooper Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC - CNS Greg Pick USNRC - Region IV NPG Distribution CNS Records
NLS201 5083 Attachment Page 1 of 1 LIST OF REGULATORY COMMITMENTS This table identifies actions discussed in this letter which Nebraska Public Power District commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not regulatory commitments.
TYPE (Check one)
SCHEDULED COMMITMENT/COMMITMENT NO.
ONE-TIME CONTINUING CMLTO ACTION COMPLIANCE DT NPPD will remove sludge and inspect the X
End of period of wetted portion of the torus every refueling extended outage from now until the end of the period operation of extended operation.
(NLS2010050-02 Rev. 1)
NPPD will complete an analysis following X
End of period of each torus inspection that demonstrates that extended the projected pitting of the torus up to the operation next inspection interval will not result in reduction of torus wall thickness below minimum acceptable values.
(NLS2010050-03 Rev. 1)