ML101520489: Difference between revisions
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
(2 intermediate revisions by the same user not shown) | |||
Line 17: | Line 17: | ||
=Text= | =Text= | ||
{{#Wiki_filter:June 16, 2010 | {{#Wiki_filter:June 16, 2010 LICENSEE: Nebraska Public Power District FACILITY: Cooper Nuclear Station | ||
LICENSEE: | |||
==SUBJECT:== | ==SUBJECT:== | ||
==SUMMARY== | ==SUMMARY== | ||
OF TELEPHONE CONFERENCE CALL HELD ON MAY 18, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY | OF TELEPHONE CONFERENCE CALL HELD ON MAY 18, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND NEBRASKA PUBLIC POWER DISTRICT, RELATED TO A CLARIFICATION FOR CERTAIN RESPONSES TO 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 May 18, 2010, to discuss clarifications for certain responses to requests for additional information for Cooper Nuclear Station license renewal. 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 | |||
As stated cc w/encls: | |||
ML101520489 OFFICE PM:RPB1:DLR LA:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME TTran IKing B. Brady BPham TTran DATE 6/07/10 6/07/10 6/14/10 6/14/10 6/16/10 Memorandum to Nebraska Public Power District from T. Tran dated June 16, 2010 | ML101520489 OFFICE PM:RPB1:DLR LA:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME TTran IKing B. Brady BPham TTran DATE 6/07/10 6/07/10 6/14/10 6/14/10 6/16/10 Memorandum to Nebraska Public Power District from T. Tran dated June 16, 2010 | ||
==SUBJECT:== | ==SUBJECT:== | ||
==SUMMARY== | ==SUMMARY== | ||
OF TELEPHONE CONFERENCE CALL HELD ON | OF TELEPHONE CONFERENCE CALL HELD ON MAY 18, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND NEBRASKA PUBLIC POWER DISTRICT, RELATED TO A CLARIFICATION FOR CERTAIN RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION, FOR COOPER NUCLEAR STATION LICENSE RENEWAL DISTRIBUTION: | ||
HARD COPY: | |||
DLR RF E-MAIL: | |||
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource TTran GMiller, RIV BBrady GPick, RIV FLyon ICouret, OPA DRoth, OGC AJones, OGC NTaylor, RIV ECollins, RIV CCasto, RIV BMaier, RIV VDricks, RIV DChamberlain, RIV AVegel, RIV WWalker, RIV | |||
Clarification for RAI B.1.3-3 Response The staff reviewed the response to request for additional information (RAI) B.1.3-3, dated May 4, 2010. The staff has the following clarification questions: | LIST OF PARTICIPANTS FROM THE TELEPHONE CONFERENCE CALL FOR COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION May 18, 2010 PARTICIPANTS AFFILIATIONS T. Tran U.S. Nuclear Regulatory Commission (NRC) | ||
: 1. To what extent has buried piping that is in the scope of license renewal been protected by the existing cathodic protection system? | B. Pham NRC D. Pelton NRC W. Holston NRC D. Alley NRC D. Bremer Nebraska Public Power District (NPPD) | ||
: 2. In the existing RAI response (RAI B.1.3-3 and NLS2010050/ML101310605), the applicant committed to visually inspect at a minimum a buried location in the service water, fire protection, and condensate make-up systems. If the applicant inspects only these three locations, what percentage of linear feet of all in scope buried pipes does this represent (to ensure representative sampling of interest)? | P. Leininger NPPD S. Freborg NPPD J. Frum NPPD B. Victor NPPD D. Lach Entergy A. Cox Entergy T. Ivy Entergy ENCLOSURE 1 | ||
: 3. In the RAI B.1.3-3 response, the applicant discussed upgrading CNS cathodic protection system. Did you intend to commit to this action (if this is a future action vs. an ongoing action and status)? | |||
COOPER NUCLEAR STATION 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 May 18, 2010, to discuss clarifications for a certain open item in the Safety Evaluation Report (SER) with Open Items for Cooper Nuclear Station (CNS) license renewal. | |||
Clarification for RAI B.1.3-3 Response The staff reviewed the response to request for additional information (RAI) B.1.3-3, dated May 4, 2010. The staff has the following clarification questions: | |||
: 1. To what extent has buried piping that is in the scope of license renewal been protected by the existing cathodic protection system? If there are different levels of protection between systems, please be prepared to discuss the degree of protection for each unique system. | |||
: 2. In the existing RAI response (RAI B.1.3-3 and NLS2010050/ML101310605), the applicant committed to visually inspect at a minimum a buried location in the service water, fire protection, and condensate make-up systems. If the applicant inspects only these three locations, what percentage of linear feet of all in scope buried pipes does this represent (to ensure representative sampling of interest)? | |||
: 3. In the RAI B.1.3-3 response, the applicant discussed upgrading CNS cathodic protection system. Did you intend to commit to this action (if this is a future action vs. an ongoing action and status)? | |||
: 4. Is there any needed RAI response supplement/follow-up RAI being planned? | : 4. Is there any needed RAI response supplement/follow-up RAI being planned? | ||
The applicant provided the following clarifications: | The applicant provided the following clarifications: | ||
: 1. There are 8 in-scope systems: (1) service water (SW), (2) condensate makeup (CM), (3) fire protection (FP), (4) off gas (OG) included as Plant Drains, (5) High Pressure Coolant Injection (HPCI), (6) diesel fuel oil (DGDO), (7) standby gas treatment (SGT), (8) nitrogen (N2). There are currently five impressed current cathodic protection systems installed at CNS. Two of the systems (protecting in-scope systems: SW, CM, FP, OG, and SGT) are located on the east side of the facility and were installed in 1973 to mitigate soil side corrosion of buried piping in the main plant area. Two additional cathodic protection systems (in-scope system: FP) were added in 1983 to provide protection to the interior submerged surfaces of two fire water storage tanks. An additional impressed applied current system (in-scope system: FP) was installed with a new warehouse facility in 1990 to provide protection to fire water piping for that facility. | : 1. There are 8 in-scope systems: (1) service water (SW), (2) condensate makeup (CM), | ||
A cathodic protection survey performed at CNS identified areas (in-scope system: DGDO) where the structure-to-oil potential measurement did not satisfy the -850 mv criteria established by NACE. In response to the survey, an upgrade of the cathodic protection system is currently in progress at CNS. Modifications include installation of four new distributed ground beds and 13 cathodic protection test stations. 2. As discussed in the RAI response, NPPD plans to perform opportunistic inspections of buried piping (in-scope systems: SW, FP, and CM) during modifications to the cathodic protection (CP) system. Exposed coating will be visually inspected for degradation before being removed, and ultrasonic wall thickness (UT) measurements will be taken at these locations with the coating removed. The examination of the piping beneath the coating provides confirmation of the effectiveness of the coating in preventing aging effects. This removal of the coating and UT is above and beyond what would typically be done during inspections under the current GALL program. NPPD will choose the most opportunistic point on one end of the line to connect the rectifier feed and the most opportunistic location on the opposite end of the line for the test station. This separation of the inspection locations provides assurance that the inspection results will provide a good indication of the state of buried pipe coatings at the CNS site. | (3) fire protection (FP), (4) off gas (OG) included as Plant Drains, (5) High Pressure Coolant Injection (HPCI), (6) diesel fuel oil (DGDO), (7) standby gas treatment (SGT), | ||
(8) nitrogen (N2). There are currently five impressed current cathodic protection systems installed at CNS. Two of the systems (protecting in-scope systems: SW, CM, FP, OG, and SGT) are located on the east side of the facility and were installed in 1973 to mitigate soil side corrosion of buried piping in the main plant area. Two additional cathodic protection systems (in-scope system: FP) were added in 1983 to provide protection to the interior submerged surfaces of two fire water storage tanks. An additional impressed applied current system (in-scope system: FP) was installed with a new warehouse facility in 1990 to provide protection to fire water piping for that facility. | |||
A cathodic protection survey performed at CNS identified areas (in-scope system: | |||
DGDO) where the structure-to-oil potential measurement did not satisfy the -850 mv criteria established by NACE. In response to the survey, an upgrade of the cathodic protection system is currently in progress at CNS. Modifications include installation of four new distributed ground beds and 13 cathodic protection test stations. | |||
ENCLOSURE 2 | |||
: 2. As discussed in the RAI response, NPPD plans to perform opportunistic inspections of buried piping (in-scope systems: SW, FP, and CM) during modifications to the cathodic protection (CP) system. Exposed coating will be visually inspected for degradation before being removed, and ultrasonic wall thickness (UT) measurements will be taken at these locations with the coating removed. The examination of the piping beneath the coating provides confirmation of the effectiveness of the coating in preventing aging effects. This removal of the coating and UT is above and beyond what would typically be done during inspections under the current GALL program. NPPD will choose the most opportunistic point on one end of the line to connect the rectifier feed and the most opportunistic location on the opposite end of the line for the test station. This separation of the inspection locations provides assurance that the inspection results will provide a good indication of the state of buried pipe coatings at the CNS site. | |||
Although these inspections will cover less than one percent of total linear feet of all in scope buried pipe, the applicant believes these are representative and valid inspections that will provide evidence of the condition of the coatings on the system piping. If degradation of the coating exists, the inspections described in the paragraph above should be able to detect it. These inspections will cover a substantial cross-section of buried piping that is representative of large segments of the in-scope buried piping since the piping has similar soil conditions, coating materials, and cathodic protection coverage. | Although these inspections will cover less than one percent of total linear feet of all in scope buried pipe, the applicant believes these are representative and valid inspections that will provide evidence of the condition of the coatings on the system piping. If degradation of the coating exists, the inspections described in the paragraph above should be able to detect it. These inspections will cover a substantial cross-section of buried piping that is representative of large segments of the in-scope buried piping since the piping has similar soil conditions, coating materials, and cathodic protection coverage. | ||
The applicant believes that implementation of the inspection plan by June 2012 in addition to the existing inspections described above in (1) prior to the period of extended operation (PEO) are sufficient to ensure that an effective representative sampling of buried piping will be inspected in a manner that ensures that the integrity of the piping is maintained. | The applicant believes that implementation of the inspection plan by June 2012 in addition to the existing inspections described above in (1) prior to the period of extended operation (PEO) are sufficient to ensure that an effective representative sampling of buried piping will be inspected in a manner that ensures that the integrity of the piping is maintained. | ||
: 3. The CP System upgrade was referenced in NPPDs response to RAI B.1.3-3 (SER Open Item 3.0.3.2-1) per NLS2010050. Efforts are underway to perform this work. While CNS fully intends to complete the CP system upgrades by August 2010, the applicant believes its program effectiveness (AMP described in LRA B.1.3 is a new program) does not rely on completion of the upgrade because of the CP reasoning listed below. Therefore, it was deemed unnecessary to make a formal commitment to complete the upgrades. | : 3. The CP System upgrade was referenced in NPPDs response to RAI B.1.3-3 (SER Open Item 3.0.3.2-1) per NLS2010050. Efforts are underway to perform this work. While CNS fully intends to complete the CP system upgrades by August 2010, the applicant believes its program effectiveness (AMP described in LRA B.1.3 is a new program) does not rely on completion of the upgrade because of the CP reasoning listed below. | ||
The condition of the CP is a factor that enters into establishing the priority and frequency of inspections through the risk ranking process. The CP upgrade effort has completed installation of a CP loop for a portion of the buried fire protection water system piping. During the installation, visual examinations of the exposed buried fire protection water piping revealed the piping segments in excellent condition with intact coating. | Therefore, it was deemed unnecessary to make a formal commitment to complete the upgrades. | ||
The condition of the CP is a factor that enters into establishing the priority and frequency of inspections through the risk ranking process. The CP upgrade effort has completed installation of a CP loop for a portion of the buried fire protection water system piping. | |||
During the installation, visual examinations of the exposed buried fire protection water piping revealed the piping segments in excellent condition with intact coating. | |||
: 4. There is no anticipated RAI response supplement/follow-up RAI at this time. | : 4. There is no anticipated RAI response supplement/follow-up RAI at this time. | ||
The staff and the applicant were in agreement on two items of mutual interests: (1) assurance of representative sampling of interest and (2) CP upgrade and inspection work are ongoing; some will be completed by 2012 and some will continue to be completed during the PEO. The staff | The staff and the applicant were in agreement on two items of mutual interests: (1) assurance of representative sampling of interest and (2) CP upgrade and inspection work are ongoing; some will be completed by 2012 and some will continue to be completed during the PEO. The staff | ||
agreed to provide a reviewing decision on the RAI B.1.3-3 response in the next conference call after the staffs review of the response. | |||
Mr. | Cooper Nuclear Station cc: | ||
Mr. Ronald D. Asche Deputy Director for Policy President and Chief Executive Officer Missouri Department of Natural Resources Nebraska Public Power District P.O. Box 176 1414 15th Street Jefferson City, MO 65102-0176 Columbus, NE 68601 Senior Resident Inspector Mr. Gene Mace U.S. Nuclear Regulatory Commission Nuclear Asset Manager P.O. Box 218 Nebraska Public Power District Brownville, NE 68321 P.O. Box 98 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Mr. John C. McClure 612 E. Lamar Blvd., Suite 400 Vice President and General Counsel Arlington, TX 76011-4125 Nebraska Public Power District P.O. Box 499 Director, Missouri State Emergency Columbus, NE 68602-0499 Management Agency P.O. Box 116 Mr. David Van Der Kamp Jefferson City, MO 65102-0116 Licensing Manager Nebraska Public Power District Chief, Radiation and Asbestos P.O. Box 98 Control Section Brownville, NE 68321 Kansas Department of Health and Environment Mr. Michael J. Linder, Director Bureau of Air and Radiation Nebraska Department of Environmental 1000 SW Jackson, Suite 310 Quality Topeka, KS 66612-1366 P.O. Box 98922 Lincoln, NE 68509-8922 Ms. Melanie Rasmussen Radiation Control Program Director Chairman Bureau of Radiological Health Nemaha County Board of Commissioners Iowa Department of Public Health Nemaha County Courthouse Lucas State Office Building, 5th Floor 1824 N Street 321 East 12th Street Auburn, NE 68305 Des Moines, IA 50319 Ms. Julia Schmitt, Manager Mr. Keith G. Henke, Planner Radiation Control Program Division of Community and Public Health Nebraska Health & Human Services R&L Office of Emergency Coordination Public Health Assurance 930 Wildwood Drive 301 Centennial Mall, South P.O. Box 570 P.O. Box 95007 Jefferson City, MO 65102 Lincoln, NE 68509-5007 | |||
Mr. Dave Lach LRP Entergy Project Manager Entergy Nuclear 1448 S.R. 333, N-GSB-45 Russellville, AR | Cooper Nuclear Station cc: | ||
Mr. Art Zaremba, Director of Nuclear Mr. Dave Lach Safety Assurance LRP Entergy Project Manager Nebraska Public Power District Entergy Nuclear P.O. Box 98 1448 S.R. 333, N-GSB-45 Brownville, NE 68321 Russellville, AR 72802 Mr. John F. McCann, Director Mr. Stewart B. Minahan Licensing, Entergy Nuclear Northeast Vice President Entergy Nuclear Operations, Inc. Nuclear and Chief Nuclear Officer 440 Hamilton Avenue Cooper Nuclear Station White Plains, NY 10601-1813 72676 - 648A Avenue Brownville, NE 68321 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. 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}} |
Latest revision as of 23:48, 11 March 2020
ML101520489 | |
Person / Time | |
---|---|
Site: | Cooper |
Issue date: | 06/16/2010 |
From: | Tam Tran License Renewal Projects Branch 1 |
To: | Office of Nuclear Reactor Regulation |
Tran, T NRR/ADRO/DLR/RPB1, 415-3617 | |
References | |
Download: ML101520489 (9) | |
Text
June 16, 2010 LICENSEE: Nebraska Public Power District FACILITY: Cooper Nuclear Station
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON MAY 18, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND NEBRASKA PUBLIC POWER DISTRICT, RELATED TO A CLARIFICATION FOR CERTAIN RESPONSES TO 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 May 18, 2010, to discuss clarifications for certain responses to requests for additional information for Cooper Nuclear Station license renewal. 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
ML101520489 OFFICE PM:RPB1:DLR LA:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME TTran IKing B. Brady BPham TTran DATE 6/07/10 6/07/10 6/14/10 6/14/10 6/16/10 Memorandum to Nebraska Public Power District from T. Tran dated June 16, 2010
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON MAY 18, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND NEBRASKA PUBLIC POWER DISTRICT, RELATED TO A CLARIFICATION FOR CERTAIN RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION, FOR COOPER NUCLEAR STATION LICENSE RENEWAL DISTRIBUTION:
HARD COPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource TTran GMiller, RIV BBrady GPick, RIV FLyon ICouret, OPA DRoth, OGC AJones, OGC NTaylor, RIV ECollins, RIV CCasto, RIV BMaier, RIV VDricks, RIV DChamberlain, RIV AVegel, RIV WWalker, RIV
LIST OF PARTICIPANTS FROM THE TELEPHONE CONFERENCE CALL FOR COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION May 18, 2010 PARTICIPANTS AFFILIATIONS T. Tran U.S. Nuclear Regulatory Commission (NRC)
B. Pham NRC D. Pelton NRC W. Holston NRC D. Alley NRC D. Bremer Nebraska Public Power District (NPPD)
P. Leininger NPPD S. Freborg NPPD J. Frum NPPD B. Victor NPPD D. Lach Entergy A. Cox Entergy T. Ivy Entergy ENCLOSURE 1
COOPER NUCLEAR STATION 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 May 18, 2010, to discuss clarifications for a certain open item in the Safety Evaluation Report (SER) with Open Items for Cooper Nuclear Station (CNS) license renewal.
Clarification for RAI B.1.3-3 Response The staff reviewed the response to request for additional information (RAI) B.1.3-3, dated May 4, 2010. The staff has the following clarification questions:
- 1. To what extent has buried piping that is in the scope of license renewal been protected by the existing cathodic protection system? If there are different levels of protection between systems, please be prepared to discuss the degree of protection for each unique system.
- 2. In the existing RAI response (RAI B.1.3-3 and NLS2010050/ML101310605), the applicant committed to visually inspect at a minimum a buried location in the service water, fire protection, and condensate make-up systems. If the applicant inspects only these three locations, what percentage of linear feet of all in scope buried pipes does this represent (to ensure representative sampling of interest)?
- 3. In the RAI B.1.3-3 response, the applicant discussed upgrading CNS cathodic protection system. Did you intend to commit to this action (if this is a future action vs. an ongoing action and status)?
The applicant provided the following clarifications:
- 1. There are 8 in-scope systems: (1) service water (SW), (2) condensate makeup (CM),
(3) fire protection (FP), (4) off gas (OG) included as Plant Drains, (5) High Pressure Coolant Injection (HPCI), (6) diesel fuel oil (DGDO), (7) standby gas treatment (SGT),
(8) nitrogen (N2). There are currently five impressed current cathodic protection systems installed at CNS. Two of the systems (protecting in-scope systems: SW, CM, FP, OG, and SGT) are located on the east side of the facility and were installed in 1973 to mitigate soil side corrosion of buried piping in the main plant area. Two additional cathodic protection systems (in-scope system: FP) were added in 1983 to provide protection to the interior submerged surfaces of two fire water storage tanks. An additional impressed applied current system (in-scope system: FP) was installed with a new warehouse facility in 1990 to provide protection to fire water piping for that facility.
A cathodic protection survey performed at CNS identified areas (in-scope system:
DGDO) where the structure-to-oil potential measurement did not satisfy the -850 mv criteria established by NACE. In response to the survey, an upgrade of the cathodic protection system is currently in progress at CNS. Modifications include installation of four new distributed ground beds and 13 cathodic protection test stations.
ENCLOSURE 2
- 2. As discussed in the RAI response, NPPD plans to perform opportunistic inspections of buried piping (in-scope systems: SW, FP, and CM) during modifications to the cathodic protection (CP) system. Exposed coating will be visually inspected for degradation before being removed, and ultrasonic wall thickness (UT) measurements will be taken at these locations with the coating removed. The examination of the piping beneath the coating provides confirmation of the effectiveness of the coating in preventing aging effects. This removal of the coating and UT is above and beyond what would typically be done during inspections under the current GALL program. NPPD will choose the most opportunistic point on one end of the line to connect the rectifier feed and the most opportunistic location on the opposite end of the line for the test station. This separation of the inspection locations provides assurance that the inspection results will provide a good indication of the state of buried pipe coatings at the CNS site.
Although these inspections will cover less than one percent of total linear feet of all in scope buried pipe, the applicant believes these are representative and valid inspections that will provide evidence of the condition of the coatings on the system piping. If degradation of the coating exists, the inspections described in the paragraph above should be able to detect it. These inspections will cover a substantial cross-section of buried piping that is representative of large segments of the in-scope buried piping since the piping has similar soil conditions, coating materials, and cathodic protection coverage.
The applicant believes that implementation of the inspection plan by June 2012 in addition to the existing inspections described above in (1) prior to the period of extended operation (PEO) are sufficient to ensure that an effective representative sampling of buried piping will be inspected in a manner that ensures that the integrity of the piping is maintained.
- 3. The CP System upgrade was referenced in NPPDs response to RAI B.1.3-3 (SER Open Item 3.0.3.2-1) per NLS2010050. Efforts are underway to perform this work. While CNS fully intends to complete the CP system upgrades by August 2010, the applicant believes its program effectiveness (AMP described in LRA B.1.3 is a new program) does not rely on completion of the upgrade because of the CP reasoning listed below.
Therefore, it was deemed unnecessary to make a formal commitment to complete the upgrades.
The condition of the CP is a factor that enters into establishing the priority and frequency of inspections through the risk ranking process. The CP upgrade effort has completed installation of a CP loop for a portion of the buried fire protection water system piping.
During the installation, visual examinations of the exposed buried fire protection water piping revealed the piping segments in excellent condition with intact coating.
The staff and the applicant were in agreement on two items of mutual interests: (1) assurance of representative sampling of interest and (2) CP upgrade and inspection work are ongoing; some will be completed by 2012 and some will continue to be completed during the PEO. The staff
agreed to provide a reviewing decision on the RAI B.1.3-3 response in the next conference call after the staffs review of the response.
Cooper Nuclear Station cc:
Mr. Ronald D. Asche Deputy Director for Policy President and Chief Executive Officer Missouri Department of Natural Resources Nebraska Public Power District P.O. Box 176 1414 15th Street Jefferson City, MO 65102-0176 Columbus, NE 68601 Senior Resident Inspector Mr. Gene Mace U.S. Nuclear Regulatory Commission Nuclear Asset Manager P.O. Box 218 Nebraska Public Power District Brownville, NE 68321 P.O. Box 98 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Mr. John C. McClure 612 E. Lamar Blvd., Suite 400 Vice President and General Counsel Arlington, TX 76011-4125 Nebraska Public Power District P.O. Box 499 Director, Missouri State Emergency Columbus, NE 68602-0499 Management Agency P.O. Box 116 Mr. David Van Der Kamp Jefferson City, MO 65102-0116 Licensing Manager Nebraska Public Power District Chief, Radiation and Asbestos P.O. Box 98 Control Section Brownville, NE 68321 Kansas Department of Health and Environment Mr. Michael J. Linder, Director Bureau of Air and Radiation Nebraska Department of Environmental 1000 SW Jackson, Suite 310 Quality Topeka, KS 66612-1366 P.O. Box 98922 Lincoln, NE 68509-8922 Ms. Melanie Rasmussen Radiation Control Program Director Chairman Bureau of Radiological Health Nemaha County Board of Commissioners Iowa Department of Public Health Nemaha County Courthouse Lucas State Office Building, 5th Floor 1824 N Street 321 East 12th Street Auburn, NE 68305 Des Moines, IA 50319 Ms. Julia Schmitt, Manager Mr. Keith G. Henke, Planner Radiation Control Program Division of Community and Public Health Nebraska Health & Human Services R&L Office of Emergency Coordination Public Health Assurance 930 Wildwood Drive 301 Centennial Mall, South P.O. Box 570 P.O. Box 95007 Jefferson City, MO 65102 Lincoln, NE 68509-5007
Cooper Nuclear Station cc:
Mr. Art Zaremba, Director of Nuclear Mr. Dave Lach Safety Assurance LRP Entergy Project Manager Nebraska Public Power District Entergy Nuclear P.O. Box 98 1448 S.R. 333, N-GSB-45 Brownville, NE 68321 Russellville, AR 72802 Mr. John F. McCann, Director Mr. Stewart B. Minahan Licensing, Entergy Nuclear Northeast Vice President Entergy Nuclear Operations, Inc. Nuclear and Chief Nuclear Officer 440 Hamilton Avenue Cooper Nuclear Station White Plains, NY 10601-1813 72676 - 648A Avenue Brownville, NE 68321 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. 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