NLS2024009, Response to Nuclear Regulatory Commission Request for Additional Information Regarding Application to Revise Technical Specifications to Support Inspection of
| ML24071A140 | |
| Person / Time | |
|---|---|
| Site: |  |
| Issue date: | 03/08/2024 |
| From: | Dia K Nebraska Public Power District (NPPD) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NLS2024009 | |
| Download: ML24071A140 (1) | |
Text
H Nebraska Public Power District
Always there when you need us"
50.90
NLS2024009 March 08, 2024
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Nuclear Regulatory Commission Request for Additional Information Regarding Application to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No.
References:
- 1. Email from Thomas Byrd, U.S. Nuclear Regulatory Commission, to Linda Dewhirst, Nebraska Public Power District, dated February 1, 2024, "Cooper -
RAI - LAR DFO Tank Inspections (EPID L-2023-LLA-0126)"
- 2. Letter from Khalil Dia, Nebraska Public Power District, to the U.S. Nuclear Regulatory Commission, dated September 6, 2023, "License Amendment Request to Revise Cooper Nuclear Station Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks"
Dear Sir or Madam:
The purpose of this letter is for the Nebraska Public Power District (NPPD) to respond to the Nuclear Regulatory Commission's (NRC) Request for Additional Information (RAI) (Reference
- 1) related to the Cooper Nuclear Station (CNS) "License Amendment Request to Revise Cooper Nuclear Station Technical Specifications [TS] to Support Inspection of Diesel Fuel Oil Storage Tanks" (Reference 2).
The response to the RAI is provided in Attachment 1 to this letter. Attachment 2 contains revised TS marked up pages. Attachment 3 contains revised ( clean) TS pages. Attachment 4 contains revised marked up TS Bases pages for information only.
NPPD has reviewed the information supporting a finding of no significant hazards consideration and the environmental evaluation that were previously provided to the NRC in Reference 2. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration and does not affect the conclusion of the environmental evaluation.
This letter does not contain any new regulatory commitments.
COOPER NUCLEAR STATION 72676 648A Ave/ P.O. Box 98 I Brownville, NE 68321 http://www.nppd.com NLS2024009 Page 2 of2
If you have any questions concerning this matter, please contact Linda Dewhirst, Regulatory Affairs and Compliance Manager, at ( 402) 825-5416.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: 3/ B / 2-l{
(Date)
Sincerely,
~-
Khalil Dia Site Vice President
/dv
Attachments: 1. Response to Request for Additional Information
- 2. Proposed Technical Specifications Change (Mark-up)
- 3. Revised Technical Specifications Pages
- 4. Revised Technical Specifications Bases Pages
cc: Regional Administrator w/ attachments USNRC - Region IV
Cooper Project Manager w/ attachments USNRC - NRR Plant Licensing Branch IV
Senior Resident Inspector w/ attachments USNRC- CNS
Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure
NPG Distribution w/ attachments
CNS Records w/ attachments NLS2024009 Attachment 1 Page 1 of3
Attachment 1
Response to Request for Additional Information
Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46
The Nuclear Regulatory Commission (NRC) Request for Additional Information regarding the License Amendment Request for Cooper Nuclear Station (CNS) Technical Specifications (TS) to Support Inspection of Diesel Fuel Oil Storage Tanks (FOST) is shown in italics. The Nebraska Public Power District (NPPD) response to the request is shown in normal font.
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 staff's 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 note's 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.
NLS2024009 Attachment 1 Page 2 of3
- 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 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 hours. 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.
NPPD Response
Question 1 a: Based on the conference call between the NRC and NPPD on January 31, 2024, the proposed Note 2 is being revised to recognize that the diesel fuel oil storage tanks are considered inoperable when drained for cleaning, inspection, repair, and testing. During the maintenance windows for the two tanks, Condition A and F are not required to be entered providing the following are satisfied:
- a. 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.
- b. Verify once per 24 hours that the FOSTs and temporary storage tanks combined contain at least a 7-day supply of fuel oil.
- c. The compensatory measures contained in Attachment 2 of Nebraska Public Power District letter NLS2023029 are met.
- d. FOSTs must be restored within 14 days.
If notes "a" through "d" are not satisfied, Condition F is entered.
The revision to the proposed Note 2 includes exceptions to entering Conditions A and F. With this revision, it is appropriate to locate the proposed note at the beginning of the Actions section of TS 3.8.3. In addition, a Completion Time of 14 days for each tank maintenance window is included. The requested 14-day Completion Time includes some margin should the evolution take longer than expected, providing time to complete any necessary repair, if required. This proposed Note 2 aligns with the Monticello precedence cited in the license amendment request.
The Monticello amendment included a note that the Surveillance Requirement (SR) 3.8.1.5 for verifying the fuel oil transfer system operates to transfer fuel oil from the storage tank to the day tank is not applicable. This note is not necessary for CNS as the CNS equivalent, SR 3.8.1.6, would apply to the fuel oil storage tank that will still be in service for the required diesel generator, with a fuel oil transfer pump in automatic.
Question 1 b: The intent of the third sentence in the proposed Note 2 was to clarify that the temporary tanks, in conjunction with the permanent tanks, were required to meet all TS requirements related to volume and chemistry (total particulates). This same sentence was used in the 2004 submittal referenced in the license amendment request. NPPD understands how the sentence can be ambiguous. With the revisions based on the Question 1 a response, this sentence NLS2024009 Attachment 1 Page 3 of 3
was removed. This will help minimize confusion in the application of TS regarding the use of the proposed Note 2.
Attachment 2 contains new marked up TS pages and Attachment 3 contains new, clean typed TS pages that reflect the changes discussed in Questions 1 a and 1 b above. With the revision of the proposed Note 2 taking more space on page 3.8-13, Conditions Band Chad to be relocated to the following page, 3.8-14. Attachment 4 contains a revised TS Bases page for information only.
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.
NPPD Response
The project special procedures will include work stand-down and no-start guidance when severe weather is forecast and will utilize station Emergency Procedure 5 .1 WEATHER for identifying "severe weather" and mitigating actions. The temporary fuel transfer equipment will consist of a high flow pump and filter unit. The filter unit is integral to a heavy vehicle and the high flow pump is skid mounted with a diesel engine to provide a power source independent of the station.
The filter vehicle and pump skid are not considered subject to physical displacement by high winds. The filter vehicle and pump skid will be stored on the station's east road when not in operation and away from critical off-site power sources, i.e., Emergency Station Service Transformer and Startup Station Service Transformer, and the associated overhead grid supply lines. If the mobile pump and filter are in use when severe weather is identified, actions will be taken in accordance with Emergency Procedure 5.1 WEATHER to ensure personnel safety and relocate vulnerable equipment.
Required temporary fuel transfer hoses and associated connectors and tools will be staged near the temporary tanks on the station's east road and away from off-site power sources. The project special procedures and Emergency Procedure 5 .1 WEATHER will be utilized to direct actions to secure loose materials associated with in-progress tank cleaning and the temporary transfer hoses, connectors, and tools. Direction for securing loose equipment will include re-locating the loose temporary hoses, connectors, and tools to an indoor staging area to ensure the equipment is protected from severe weather. These actions combined with standard housekeeping practices, actions already included in Emergency Procedure 5.lWEATHER and maintaining four days of fuel within the in-service permanent storage tank will ensure severe weather will not challenge the ability to transfer fuel from the temporary tanks or result in producing wind generated missiles which can impact safety-related equipment.
NLS2024009 Page 1 of 3
Attachment 2
Proposed Technical Specifications Change (Mark-up)
Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46
Revised Pages
3.8-13 3.8-14 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
3.8 ELECTRICAL POWER SYSTEMS
3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air
LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).
APPLICABILITY: When associated DG is required to be OPERABLE.
ACTIONS
NOTES----------------------------------------------------------
- 1. Separate Condition entry is allowed for each DG, except for Conditions A, C, and D.
- 2. During Refuel Outage 33, a diesel fuel oil storage tank (FOST) may be made inoperable and drained to support cleaning, inspection. testing. and associated repair activities without entering Conditions A and F, provided the following are satisfied:
- a. 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.
- b. Verify once per 24 hours that the FOSTs and temporary storage tanks combined contain at least a 7-day supply of fuel oil.
- c. The compensatory measures contained in Attachment 2 of Nebraska Public Power District letter NLS2023029 are met.
- d. FOSTs must be restored within 14 days.
If Notes 2.a through 2.d are not satisfied. enter Condition F.
Each tank will be drained separately during associated divisional window. This temporary note is applicable only during Refuel Outage 33 while in MODES 4 or 5.
CONDITION REQUIRED ACTION COMPLETION TIME
A. Fuel oil level less than a 7 A.1 Restore fuel oil level to 48 hours day supply and greater than within limits.
a 6 day supply in storage tanks.
(continued)
Cooper 3.8-13 Amendment No. xxx Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
B. One or more DGs with lube B.1 Restore lube oil inventory 48 hours oil inventory less than a 7 to within limits.
day supply and greater than a 6 day supply.
C. Stored fuel oil total C. 1 Restore stored fuel oil total 7 days particulates not within limit. particulates to within limit.
D. New fuel oil properties not D.1 Restore stored fuel oil 30 days within limits. properties to within limits.
E. One or more DGs with E.1 Restore starting air 48 hours starting air receiver pressure receiver pressure to 2! 200
< 200 psig and 2! 125 psig. psig.
F. Required Action and F.1 Declare associated DG( s) Immediately associated Completion Time inoperable.
of Condition A, B, C, D, or E not met.
One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.
Cooper 3.8-14 Amendment No. xxx NLS2024009 Page 1 of 3
Attachment 3
Revised Technical Specifications Pages
Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46
Revised Pages
3.8-13 3.8-14 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
3.8 ELECTRICAL POWER SYSTEMS
3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air
LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).
APPLICABILITY: When associated DG is required to be OPERABLE.
ACTIONS
NO TES----------------------------------------------------------
- 1. Separate Condition entry is allowed for each DG, except for Conditions A, C, and D.
- 2. During Refuel Outage 33, a diesel fuel oil storage tank (FOST) may be made inoperable and drained to support cleaning, inspection, testing, and associated repair activities without entering Conditions A and F, provided the following are satisfied:
- a. 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.
- b. Verify once per 24 hours that the FOSTs and temporary storage tanks combined contain at least a 7-day supply of fuel oil.
- c. The compensatory measures contained in Attachment 2 of Nebraska Public Power District letter NLS2023029 are met.
- d. FOSTs must be restored within 14 days.
If Notes 2.a through 2.d are not satisfied, enter Condition F.
Each tank will be drained separately during associated divisional window. This temporary note is applicable only during Refuel Outage 33 while in MODES 4 or 5.
CONDITION REQUIRED ACTION COMPLETION TIME
A. Fuel oil level less than a 7 A.1 Restore fuel oil level to 48 hours day supply and greater than within limits.
a 6 day supply in storage tanks.
( continued)
Cooper 3.8-13 Amendment No. xxx Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
ACTIONS ( continued)
CONDITION REQUIRED ACTION COMPLETION TIME
B. One or more DGs with lube B.1 Restore lube oil inventory 48 hours oil inventory less than a 7 to within limits.
day supply and greater than a 6 day supply.
C. Stored fuel oil total C.1 Restore stored fuel oil total 7 days particulates not within limit. particulates to within limit.
D. New fuel oil properties not D.1 Restore stored fuel oil 30 days within limits. properties to within limits.
E. One or more DGs with E.1 Restore starting air 48 hours starting air receiver pressure receiver pressure to ~ 200
< 200 psig and ~ 125 psig. psig.
F. Required Action and F.1 Declare associated DG( s) Immediately associated Completion Time inoperable.
of Condition A, B, C, D, or E not met.
One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.
Cooper 3.8-14 Amendment No. xxx NLS2024009 Page 1 of 3
Attachment 4
Revised Technical Specifications Bases Pages
Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46
Revised Pages
B 3.8-31 B 3.8-32 Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3
BASES
ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG except for Conditions A, C, and D.
This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem.
Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) governed by separate Condition entry and application of associated Required Actions. The Note does not apply to Conditions A, C and D since the CNS design has two fuel oil storage tanks that supply fuel oil to both DGs.
Note 2 is a temporary note that allows a diesel fuel oil storage tank (FOST) to be made inoperable and drained to support cleaning.
inspection testing. and associated repair activities without entering Conditions A and F if certain conditions are met.
- a. 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.
A temporary transfer pump with a capacity greater than 15 gpm must be pre-staged and available to transfer the temporary storage tank fuel oil and out-of-service permanent storage tank fuel oil. This is considered sufficient based on fuel in the in-service permanent tank providing a minimum of 4 days full load operation of the DG. contingency measures which pre-stage equipment necessary to supply fuel oil to the in-service permanent tank or directly to the DG day tank, and the initiation of action to obtain replenishment fuel.
- b. The FOSTs and temporary tanks combined will be verified to contain a 7-day supply of fuel oil on a 24-hour frequency.
Periodic verification of the required volume to allow for a 7-day supply of fuel oil to the required DG is essential to meet the licensing basis for DG operation. During fuel movement between the permanent tanks and temporary tanks. the overall fuel oil storage volume contained within all the tanks may be used to meet the 7-day requirement.
C. Additional compensatory measures that must be met. before and during the maintenance activity. are listed in Attachment 2 of NLS2023029.
These compensatory measures and the temporary fuel oil system ensure the fuel oil volume required for the 7-day requirement is met.
Cooper B 3.8-31============xx/xx/xx Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3
BASES
ACTIONS (completed)
- d. Each FOST may be taken out of service for up to 14 days.
Condition F must be entered if any Note 2 condition is not met or the 14-day completion time is reached.
This temporary note is applicable only during Refuel Outage 33 while in MODES 4 or 5.
In this Condition, the 7 day fuel oil supply for both DGs is not available.
The 49,500 gallon limit is a conservative estimate of the required fuel oil based on worst case fuel consumption. However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply.
The fuel oil level equivalent to a 6 day supply is 42,800 gallons. These circumstances may be caused by events such as:
- a. Full load operation required for an inadvertent start while at minimum required level; or
- b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours is considered sufficient to complete restoration of the required level prior to declaring the DGs inoperable. This period is acceptable based on the remaining capacity(> 6 days), the fact that action will be initiated to obtain replenishment, and the low probability of an event during this brief period.
In this Condition, the 7 day lube oil inventory, i.e., sufficient lube oil to support 7 days of continuous DG operation at full load conditions, is not available. However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply. The lube oil inventory equivalent to a 6 day supply is 432 gallons. This restriction allows sufficient time for obtaining the requisite replacement volume. A period of 48 hours is considered sufficient to complete restoration of the required volume prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the low rate of usage, the fact that action
Cooper B 3.8-32=============xx/xx/xx