ML092380434

07/07/2009 Meeting Summary, Telephone Conference Call Between the U.S. NRC Staff and Nebraska Public Power District, Related to a Clarification for Certain Requests for Additional Information, for Cooper Nuclear Station License Renewal

ML092380434
Person / Time
Site:	Cooper
Issue date:	09/17/2009
From:	Tam Tran License Renewal Projects Branch 1
To:	Nebraska Public Power District (NPPD)
SAYOC E, NRR/DLR/RPB2, 415-1924
References
Download: ML092380434 (11)

Text

September 17, 2009 LICENSEE: Nebraska Public Power District

FACILITY: Cooper Nuclear Station

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JULY 7, 2009, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND NEBRASKA PUBLIC POWER DISTRICT, RELATED TO A CLARIFICATION FOR CERTAIN REQUESTS FOR ADDITIONAL INFORMATION FOR COOPER NUCLEAR STATION LICENSE RENEWAL The U.S. Nuclear Regulatory Commission staff and representatives of Nebraska Public Power District held a telephone conference call on July 7, 2009, to discuss clarifications for certain draft requests for additional information for Cooper Nuclear Station license renewal.

Enclosure 1 provides a listing of the participants, and Enclosure 2 contains a brief description of the conference call.

The applicant had an opportunity to comment on this summary.

/RA/

Tam Tran, Project Manager License Renewal Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation

Docket No. 50-298

Enclosures:

As stated

cc w/encls: See next page

ML092380434 OFFICE LA:DLR PM:RPB1:DLR PM:RPB2:DLR BC:RPB1:DLR PM:RPB2:DLR NAME I. King B. Brady T. Tran D. Pelton T. Tran (Signature) DATE 09/03/09 09/04/09 09/14/09 09/17/09 09/17/09 Memorandum to Nebraska Public Power District from Tam Tran dated September 17, 2009

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JULY 7, 2009, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND NEBRASKA PUBLIC POWER DISTRICT, RELATED TO A CLARIFICATION FOR CERTAIN REQUESTS FOR ADDITIONAL INFORMATION FOR COOPER NUCLEAR STATION LICENSE RENEWAL DISTRIBUTION

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T. Tran E. Sayoc B. Brady F. Lyon I.Couret D. Roth (OGC) A. Jones (OGC) N. Taylor (RIV) E. Collins (RIV) C. Casto (RIV) B. Maier (RIV)

V. Dricks (RIV) D. Chamberlain (RIV) A. Vegel (RIV) W. Walker (RIV) G. Miller (RIV)

G. Pick (RIV)

Cooper Nuclear Station cc: Mr. Ronald D. Asche President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. Gene Mace Nuclear Asset Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. John C. McClure Vice President and General Counsel Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 Mr. David Van Der Kamp Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321

Mr. Michael J. Linder, Director Nebraska Department of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922

Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R&L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Deputy Director for Policy Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 218 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125

Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116

Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366 Ms. Melanie Rasmussen Radiation Control Program Director Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319 Mr. Keith G. Henke, Planner Division of Community and Public Health Office of Emergency Coordination 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102

Cooper Nuclear Station cc: Mr. Art Zaremba, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. John F. McCann, Director Licensing, Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601-1813 Mr. Mike Boyce Cooper Strategic Initiatives Manager Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321 Mr. Dave Bremer License Renewal Project Manager Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321

Mr. Bill Victor License Renewal Project Licensing Lead Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321

Mr. Jim Loynes License Renewal Project Engineer Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321 Mr. Garry Young License Renewal Manager Entergy Nuclear 1448 S.R. 333, N-GSB-45 Russellville, AR 72802

Mr. Alan Cox License Renewal Technical Manager Entergy Nuclear 1448 S.R. 333, N-GSB-45 Russellville, AR 72802 Mr. Dave Lach LRP Entergy Project Manager Entergy Nuclear 1448 S.R. 333, N-GSB-45 Russellville, AR 72802 Mr. Stewart B. Minahan Vice President Nuclear and Chief Nuclear Officer Cooper Nuclear Station 72676 - 648A Avenue Brownville, NE 68321 ENCLOSURE 1 LIST OF PARTICIPANTS TELEPHONE CONFERENCE CALL COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION JULY 7, 2009 PARTICIPANTS AFFILIATIONS Tam Tran U.S. Nuclear Regulatory Commission (NRC) Brian Harris NRC Abdul Sheikh NRC Emmanuel Sayoc NRC On Yee NRC Seung Min NRC Ganesh Cheruvenki NRC Albert Wong NRC Dave Bremer Nebraska Public Power District (NPPD)

Jim Loynes NPPD Scott Freborg NPPD Dave Lach Entergy Nuclear Operations, Inc. (Entergy)

Alan Cox Entergy Don Fronabarger Entergy Andrew Taylor Entergy

ENCLOSURE 2 COOPER NUCLEAR STATION POWER PLANT LICENSE RENEWAL APPLICATION (Brief description of the conference call)

The U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Nebraska Public Power District (NPPD) held a telephone conference call on July 7, 2009, to discuss clarifications for certain draft requests for additional information related to the Cooper Nuclear Station (CNS) license renewal application listed below.

Draft Request for Additional Information (D-RAI) B.1.9-4

Background

According to Generic Aging Lessons Learned (GALL) aging management review line Item IV B1-14, cumulative fatigue evaluation as part of a time-limited aging analysis (TLAA) for core shroud components is recommended.

Issue In Section 5.5 of the applicant's report CR-CNS-07-LRD04, "CNS Licensing Renewal Project -

TLAA-Mechanical Fatigue," the applicant stated that the fatigue evaluation of the core shroud components is not based on the life of the plant, and therefore, it is not a TLAA.

Request Provide an explanation for not performing a TLAA evaluation for the core shroud components.

If this is not a TLAA, how is the degradation due to fatigue managed for the core shroud components.

Discussion The applicant indicated that the question is clear. This draft RAI will be sent as a formal RAI.

D-RAI B.1.38-2

Background

License renewal application (LRA) Section B.1.38, "Water Chemistry Control - Auxiliary Systems" description states in part: "Program activities include sampling and analysis of water in auxiliary condensate drain system components, auxiliary steam system components, and heating and ventilation system components to minimize component exposure to aggressive environments."

Under "3. Parameters Monitored/Inspected," it states in part: "In accordance with industry recommendations, auxiliary condensate drain system and auxiliary steam system water parameters monitored are pH, conductivity, phosphate, sulfite, and iron." Furthermore, it also states that "In accordance with industry recommendations, heating and ventilation systems parameter monitored is sodium nitrite (NaNO 2)." Under "10. Operating Experience," it states in part: "The results for the condensate and steam system indicated no variance limits in pH or conductivity with occasional variance in iron, phosphate and sulfite. Also, the results for the admin chiller system indicated no variance from limits in conductivity with occasional variance in sodium nitrites." Issue

• It is not clear to the reviewer the reason(s) why a plant-specific water chemistry control program is necessary for the auxiliary systems.

• The LRA did not include a reference to the aforementioned industry recommendations.

• The LRA did not provide details on the equipment operating characteristics (e.g., boiler pressure), parameter monitoring program (e.g., frequency of water samples being collected), or description on those incidences where the parameters (e.g., phosphate and sulfite for the boilers, and sodium nitrites for the admin chillers) exhibited variance and the associated corrective actions to return them within the limits.

Request Please provide: 1. A comparison between the plant-specific water chemistry control program and the closed-cycle cooling water system and the water chemistry program in NUREG-1801, Volume 2, and a justification as to why the GALL programs are not suitable for the auxiliary systems. 2. Any applicable reference(s) to the industry recommendations.

3. More details on (i) steam pressure, (ii) frequency of the water samples being collected, (ii) the nature, frequency of those incidences where variances had occurred, as well as the outcome and efficacy of the corrective actions. RAI B.1.38-2 (Revised)

Background

LRA Section B.1.38, "Water Chemistry Control - Auxiliary Systems" description states in part: "Program activities include sampling and analysis of water in auxiliary condensate drain system components, auxiliary steam system components, and heating and ventilation system components to minimize component exposure to aggressive environments."

Under "3. Parameters Monitored/Inspected," it states in part: "In accordance with industry recommendations, auxiliary condensate drain system and auxiliary steam system water parameters monitored are pH, conductivity, phosphate, sulfite, and iron." Furthermore, it also states that "In accordance with industry recommendations, heating and ventilation systems parameter monitored is sodium nitrite (NaNO 2)." Under "10. Operating Experience," it states in part: "The results for the condensate and steam system indicated no variance limits in pH or conductivity with occasional variance in iron, phosphate and sulfite. Also, the results for the admin chiller system indicated no variance from limits in conductivity with occasional variance in sodium nitrites."

Issue

• It is not clear to the reviewer the reason(s) why a plant-specific water chemistry control program is necessary for the auxiliary systems.

• The LRA did not include a reference to the aforementioned industry recommendations.

• The LRA did not provide details on the equipment operating characteristics (e.g., boiler pressure), parameter monitoring program (e.g., frequency of water samples being collected), or description on those incidences where the parameters (e.g., phosphate and sulfite for the boilers, and sodium nitrites for the admin chillers) exhibited variance and the associated corrective actions to return them within the limits.

Request Please provide more details on (i) steam pressure, (ii) frequency of the water samples being collected, (ii) the nature, frequency of those incidences where variances had occurred, as well as the outcome and efficacy of the corrective actions.

Discussion The first two bulleted questions are withdrawn and will not be sent as a formal RAI based upon discussion/clarifications between the applicant and the staff. The third bulleted question was discussed and is understood by the applicant and will be sent as a formal RAI.

D-RAI B.1.7-4

Background The staff found that the American Society of Mechanical Engineers Code (ASME)Section XI, 2001 Edition, 2003 Addenda was used for the program elements, Acceptance Criteria and Corrective Actions, of the applicant's program rather than the ASME Code Section XI, 1986 Edition as recommended by the GALL Report.

Issue The edition and addenda of the ASME Code Section XI that the applicant program uses in the program are different from those the GALL Report recommends.

Request Provide the justification for the program's use of a different edition and addenda of the ASME Code Section XI for the program elements.

Discussion The staff discussed with the applicant its description, "2001 Edition 2003 Addenda" and whether or not this means that the applicant's Code Edition and Addenda include the 2002 Addenda as well as 2003 Addenda. The applicant confirmed that the term 2001 Edition 2003 Addenda means that it includes Addenda 2002 and 2003.

D-RAI 3.3.1-1

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Background===

In the LRA, the GALL Report Reactor Water Cleanup System (RWCU) aging management program is not credited for the aging management of the stainless steel inter-granular stress corrosion cracking (IGSCC) in the RWCU system. Instead, the Water Chemistry Control Program in conjunction with the One-Time Inspection Program was credited to manage the aging effect. The approach of the applicant might cause no further periodic inspections on the RWCU System.

The GALL Report recommends the following three criteria should be met to discontinue the IGSCC inspection of the RWCU system piping welds outboard of the second isolation valve. 1. Satisfactory completion of Generic Letter (GL) 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance." 2. No IGSCC detected in RWCU piping welds inboard of the second isolation valve (ongoing GL 88-01 inspection). 3. No IGSCC detected in RWCU piping welds outboard of the second isolation valve after inspecting a minimum of 10 percent of the susceptible piping welds.

The LRA Table 3.3.1, Item 3.3.1-37, indicates:

• The applicant has complied with the requirements of GL 89-10.

• Portions of the RWCU System were replaced with a stress-corrosion cracking (SCC)-resistant material.

• No significant indications of SCC were observed on the piping that was not replaced.

Issue It is not clear whether the applicant met all of the three criteria to discontinue the RWCU system inspections.

Request 1. Clarify whether all of the three criteria are met to discontinue the inspections of the outboard piping of the RWCU system. 2. If all of the three criteria are not met, clarify what inspections will be performed for the inboard and outboard portions of the RWCU system piping, respectively, over the extended period of operation.

Discussion The discussion between the applicant and the staff centered on the CNS current licensing basis (CLB) that reflects closure of the GL 88-01 inspection based on different criteria from GALL, that allowed for ceasing examination of RWCU outboard portions. In relation to criterion 2, the applicant stated that the piping inboard of the second isolation valve (four inches or greater, at or above 200 F) has been replaced with IGSCC-resistant material. It was not clear whether all relevant piping and piping welds inboard of the isolation valve were replaced including repaired welds (ex., weld overlay). The staff indicated that even in the case that all relevant inboard piping and piping welds were replaced based on the appellant's statement that the outboard piping has non-resistant material, the optional criteria involving criterion 1 and the use of non-resistant material cannot be claimed. A possible follow-up telephone conference was deemed possible.

D-RAI B.1.11-1

Background

Exemptions from 10 CFR Part 50 requirements and Operating License amendments only apply to the CLB and are time-limited. Consequently, citing approved exemptions or amendments cannot be used as a basis for taking exception to the GALL Report since they may not be renewed. Each exception to the GALL Report must be evaluated for NRC approval based on the technical bases that are associated with aging management regardless of whether there is an approved related exemption or amendment. Citing an exemption or amendment does not provide an acceptable basis to take an exception to the GALL Report. Issue The CNS LRA takes three exceptions to the GALL AMP XI.S4, "10 CFR Part 50, Appendix J," which are supported by approved 10 CFR Part 50 exemptions or license amendments.

Request Provide the technical bases, as they relate to aging management, and without referencing any exemptions, for the exceptions taken to the "10 CFR Part 50, Appendix J" GALL AMP.

Discussion Draft RAI 1.11-1 was withdrawn by the staff and will not be sent as a formal RAI based upon discussion/clarifications between the applicant and the staff.

Discussion The staff had a follow-up question in regards to the applicant's response to B.1.29-1. The discussion clarified that although material-environment combinations biased at susceptible locations established the sampling population criteria (i.e., did not further segregate sample populations by each possible aging effect), the examinations would include criteria for evaluating all relevant aging effects at said susceptible locations. This question was resolved.