ML041390474
| ML041390474 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/18/2004 |
| From: | Michelle Honcharik NRC/NRR/DLPM/LPD4 |
| To: | Edington R Nebraska Public Power District (NPPD) |
| Honcharik M, NRR/DLPM, 301-415-1774 | |
| References | |
| TAC MC2061, TAC MC2062 | |
| Download: ML041390474 (7) | |
Text
May 18, 2004 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUESTS RI-17 AND RI-31 (TAC NOS. MC2061 AND MC2062)
Dear Mr. Edington:
By letter dated February 12, 2004, Nebraska Public Power District (the licensee) requested the Nuclear Regulatory Commission (NRC) staff grant relief from certain inservice inspection requirements, including RI-17 and RI-31. RI-17 requests approval to eliminate disassembling the pipe clamp or restraint to examine welded attachments and examining them to the maximum extent possible in accordance with applicable Code requirements. RI-31 requests that the austenitic welds that are not accessible for inspection from both sides will be inspected from the one side that is accessible.
The NRC staff has reviewed the information provided in the February 12, 2004, submittal and determined that additional information is required in order to complete the review of RI-17 and RI-31. As agreed upon in a telephone call on May 17, 2004, the licensee will respond to each request for additional information (RAI) within 45 days. The RAIs are enclosed.
Sincerely,
/RA/
Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosures:
- 1. RAI for RI-17
- 2. RAI for RI-31 cc w/encl: See next page
May 18, 2004 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUESTS RI-17 AND RI-31 (TAC NOS. MC2061 AND MC2062)
Dear Mr. Edington:
By letter dated February 12, 2004, Nebraska Public Power District (the licensee) requested the Nuclear Regulatory Commission (NRC) staff grant relief from certain inservice inspection requirements, including RI-17 and RI-31. RI-17 requests approval to eliminate disassembling the pipe clamp or restraint to examine welded attachments and examining them to the maximum extent possible in accordance with applicable Code requirements. RI-31 requests that the austenitic welds that are not accessible for inspection from both sides will be inspected from the one side that is accessible.
The NRC staff has reviewed the information provided in the February 12, 2004, submittal and determined that additional information is required in order to complete the review of RI-17 and RI-31. As agreed upon in a telephone call on May 17, 2004, the licensee will respond to the each request for additional information (RAI) within 45 days. The RAIs are enclosed.
Sincerely,
/RA/
Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosures:
- 1. RAI for RI-17
- 2. RAI for RI-31 cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrDlpmLpdiv1 (RGramm)
PDIV-1 r/f RidsNrrPMMHoncharik RidsNrrLADBaxley RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn4MailCenter (KKennedy)
TChan RidsNrrDlpmDpr RidsNrrDeDpr RRodriquez ACCESSION NO: ML041390474 OFFICE PDIV-1/PM PDIV-1/LA PDIV-1/SC NAME MHoncharik EPeyton for DBaxley RGramm DATE 5/17/04 5/17/04 5/17/04 OFFICIAL RECORD COPY
ENCLOSURE 1 REQUEST FOR ADDITIONAL INFORMATION ISSUES RELATED TO RELIEF REQUEST RI-17 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 1.
RI-17 states in the "Component Identification" that the applicable Code Classes are 1 and 2, while the rest of the request pertains to Code Classes 1, 2, and 3. What are the Code Classes for this request?
2.
RI-17 identifies the Code Requirement as Code Case N-509. The NRC staff endorsed this code case in Regulatory Guide (RG) 1.147, Revision 12, "Inservice Inspection Code Acceptability-ASME Section XI, Division 1," with the condition that: "A minimum 10%
sample of integrally welded attachments for each item in each Code class per interval should be examined." Code Case N-509 was later annulled in Code Case Supplement 1 to the 2001 Edition. The NRC does not give relief from code cases. Request for relief from the code requirements must identify the particular requirements. Please identify what specific articles, paragraphs, tables, and/or figures of the 1989 Edition, No Addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI that will apply to this request.
3.
RI-17 states in the "Basis for Relief" that the 1995 Edition, 1995 Addenda, Figures IWB-2500-15, IWC-2500-5 and IWD-2500-1 for welded attachments were modified to add the following note: "Examination of surface areas may be limited to the portions of these areas that are accessible without removal of support members." Table IWB-2500-1, Examination Category B-K; Table IWC-2500-1, Examination Category C-C; and Table IWD-2500-1, Examination Category D-A identify the extent of the examination in Footnote (2) as being, "The extent of the examination includes essentially 100% of the length of the attachment weld at each attachment subject to examination." For the welded attachments affected by this request, please explain the application of Footnote (2) to Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1 and the application of the note included in Figures IWB-2500-15, IWC-2500-5 and IWD-2500-1.
4.
RI-17 states in the "Proposed Alternative Positions" that the request is applicable for the examination and acceptance of Class 1, Class 2, and Class 3 welded attachments.
Please identify the specific articles, paragraphs, tables, and/or figures in the 1995 Edition, 1996 Addenda of ASME Code Section XI that will apply to this request.
5.
The request for relief is for the third 10-year ISI interval. On what date did the third 10-year interval start?
ENCLOSURE 2 REQUEST FOR ADDITIONAL INFORMATION ISSUES RELATED TO RELIEF REQUEST RI-31 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 1.
Table RI-31-1 of RI-31 identified 30 welds with an estimated ultrasonic testing examination coverage of only 50 percent, which is less than the essentially 100 percent coverage required by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. Please provide cross-section drawings of the different configurations (one drawing may represent a group of similar configurations) that show the obstructions and limitations, describe the limitations to axial and circumferential scans, and show the transducer center ray path through the inspection volume. Identify the pipe and weld materials (ferritic, stainless steel, or Inconel).
2.
Table RI-31-1 of RI-31 provides a listing of the estimated coverage (volume) achieved in the second 10-year interval for each weld. For the third interval, please provide in the table the expected coverage (volume) examined with ASME Code Section XI, Appendix VIII qualified procedures and personnel and the coverage (volume) examined using a best effort (may be the same Appendix VIII procedures and personnel used in an unqualified application). Also, please provide an explanation for the differences in examination coverage (volume) when the second interval exceeds the sum of the third interval. The third interval is the total of the Appendix VIII coverage plus best effort coverage.
3.
The first and third paragraphs of the "Basis for Relief" section of RI-31 refer to 10 CFR 50.55a(b)(2)(xvi)(A). However, the regulatory requirements mentioned in the two paragraphs are contained in 10 CFR 50.55a(b)(2)(xv)(A) and 10 CFR 50.55a(b)(2)(xvi)(B), respectively. What regulations are being referred to in this section?
December 2003 Cooper Nuclear Station cc:
Mr. William J. Fehrman President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. Clay C. Warren Vice President - Nuclear Nebraska Public Power District P. O. Box 98 Brownville, NE 68321 Mr. John R. McPhail, General Counsel Nebraska Public Power District P. O. Box 499 Columbus, NE 68602-0499 Mr. Paul V. Fleming, Licensing and Regulatory Affairs 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. Cheryl K. Rogers, Program Manager Nebraska Health & Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P. O. Box 95007 Lincoln, NE 68509-5007 Mr. Ronald A. Kucera, Director of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Jerry Uhlmann, Director State Emergency Management Agency P. O. Box 116 Jefferson City, MO 65101 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 Mr. Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street Suite D Des Moines, IA 50309 Mr. Scott Clardy, Director Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102-0570