NLS2004083, Response to Request for Additional Information Regarding Relief Requests RI-17 and RI-31
| ML042100268 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/22/2004 |
| From: | Minahan S Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2004083, TAC MC2061, TAC MC2062 | |
| Download: ML042100268 (5) | |
Text
Nebraska Public Power District Always there when you need us 1 OCFR50.55a NLS2004083 July 22, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Request for Additional Information Regarding Relief Requests RI-17 and RI-31 Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46
Reference:
- 1. Letter to R. Edington (Nebraska Public Power District) from U.S. Nuclear Regulatory Commission dated May 18, 2004, "Request for Additional Information Regarding Relief Requests RI-17 and RI-31 (TAC Nos. MC2061 and MC2062)."
- 2. Letter to U. S. Nuclear Regulatory Commission from R. Edington (Nebraska Public Power District) dated February 12, 2004, "Inservice Inspection Relief Requests PR-03, RC-06, RC-07, RI-17, RI-31, RI-32 and RI-33" (NLS2004009).
The purpose of this letter is to respond to the Request for Additional Information (RAI) provided in Reference 1 regarding the previously submitted Relief Requests of Reference 2. After due consideration, the Nebraska Public Power District (NPPD) has elected to withdraw RI-31, pending the performance of the "best effort" coverage during Refueling Outage 22. NPPD intends to reapply for relief at a future date in accordance with 1 OCFR5O.55a(g)(5)(iv), after the results of the inspection are known and the answers to the RI-31 RAI questions can be obtained.
The questions and responses to the RAI related to Relief Request RI-17 are as follows:
Question 1:
RI-1 7 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 Classesfor this request?
Response
Code Class 3 was inadvertently omitted from the Component Identification section of ReliefRequest RI-17, Revision 2. This request applies to Code Classes 1, 2, and 3.
COOPER NUCLEAR STATION P.O. Box 98 / Bro wnville, NE 68321-0098 Telephone: (402) 825-3811 / F3x: (402) 825-5211 wrww.nppd.com
NLS2004083 Page 2 of 4 Question 2:
Response
RI-I 7 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, " wvith the condition that: "A minimunm 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 I to the 2001 Edition. The NRC does not give relieffrom code cases. Requestfor relieffrom the code requirements must identify tie partictlar requirements. Please identify what specific articles, paragraphs, tables, and/orfigures of the 1989 Edition, No Addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section AX that will apply to this request.
The Cooper Nuclear Station (CNS) Code of Record is ASME Section XI, 1989 Edition, No Addenda. The Examination Categories for which this request applies are contained in Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1 in the 1989 Edition, No Addenda for Integral Attachments. The Examination Categories are B-K-1, B-H, C-C, D-A, D-B, and D-C. Category B-H (Integral Attachments for Vessels) of the 1989 Edition, No Addenda, was added to Category B-K of the 1995 Edition, 1996 Addenda under the generic term of "Pressure Vessel Welded Attachments." Categories D-A, D-B, and D-C are combined into one Category D-A in the 1995 Edition, 1996 Addenda. The changes do not alter the total number of integral attachments under the scope of Section XI.
Items D1.10, D2.10, and D3.10 (which addresses system pressure tests) of the 1989 Edition was moved to Examination Category D-B in the 1995 Edition, 1996 Addenda. However, this request does not include system pressure tests. The 1989 Edition, No Addenda of Section XI will continue to be the applicable Code of Record for performing Item D1.10, D2.10, and D3.10 system pressure tests.
Categories D-A, D-B and D-C "Parts Examined" descriptions changed from support type in the 1989 Edition, No Addenda of the Code to type of component (i.e., vessels, piping, pumps and valves) in Category D-A in the 1995 Edition, 1996 Addenda. NPPD considers the change to be a more inclusive description and it does not alter the population of Class 3 integral attachments contained in CNS Inservice Inspection Program.
Code Case N-509 was listed under Code Requirements for informational purposes, since alternative rules of the Code case are being used at CNS. Per I OCFR50.55a(g)(4)(iv), NPPD is requesting approval to use the examination and acceptance requirements for integral welded attachments contained in Category B-K, Category C-C, and Category D-A of the 1995 Edition, 1996 Addenda of ASME Section XI. The Tables in both the Code of Record and the later Code provide the examination requirements (figure numbers), examination methods and acceptance criteria (paragraphs) for each of the items contained within the respective category.
NLS2004083 Page 3 of 4 Question 3:
RI-I 7 states in the "Basis for Relief' that the 1995 Edition, 1995 Addenda, Figures IWB-2500-15, ITWC-2500-5 and IW-D-2500-1 for welded attachments were niodified 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 ITWB-2500-1, Examination Category B-K; Table IJVC-2500-1, Examination Category C-C, and Table I WD-2500-1, Examination Category D-A identify the extent of the exanmination in Footnote (2) as being, "The extent of the examination includes essentially 1 00% 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 IWVD-2500-1 and the application of the note included in Figures IWVB-2500-15, IWC-2500-5 and ITVD-2500-1.
Response
NPPD understands the Footnote 2 to mean greater than 90 percent of the required examination volume, wvhere the reduction in coverage is due to interference by another component, or part geometry (see NRC Information Notice 98-42). This footnote is not unusual and similar footnotes are given in other Categories.
However, Footnote 2 does not negate the note given in Figures IWB-2500-15, IWC-2500-5, and IWD-2500-1. All three figures state: "Examination of surface areas may be limited to the portions of these areas that are accessible without removal of support members." NPPD understands the note contained in Figures IWB-2500-15, IWC-2500-5, and IWD-2500-1 to mean that a support item such as a pipe clamp that may cover the l/2 inch area from the end of a pipe lug weld does not have to be removed to meet the volume requirements of the attachment weld.
Question 4:
RI-I 7 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 the ASME Code Section XI that will apply to this request.
Response
As described in the Response to Question 2, NPPD is requesting approval to use the examination and acceptance requirements for integral welded attachments contained in Category B-K of Table IWB 2500-1, Category C-C of Table IWC 2500-1, and Category D-A of Table IWD 2500-1 of the 1995 Edition, 1996 Addenda of ASME Section XI. The Tables provide the examination requirements (figure numbers), examination methods and acceptance criteria (paragraphs) for each of the items contained within the respective category.
Question 5:
Tle requestfor relief isfor the third 10-yearISI interval. On what date did the third 10-year interval start?
Response
The third 10-year interval at CNS commenced on March 1, 1996.
NLS2004083 Page 4 of 4 Should you have any questions concerning this matter, please contact Mr. Paul Fleming at (402) 825-2774.
Sincerely, Stewart B. Minahan General Manager of Plant Operations
/wrv cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution Records
I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© Correspondence Number: NLS2004083 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE None 4
4 4
4
.4
.4 4
.4 PROCEDURE 0.42 REVISION 15 l
PAGE 18 OF24