ML062260195
| ML062260195 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/02/2006 |
| From: | Terao D NRC/NRR/ADRO/DORL/LPLIV |
| To: | Edington R Nebraska Public Power District (NPPD) |
| Benney B, NRR/DORL, 415-3764 | |
| References | |
| TAC MD0285 | |
| Download: ML062260195 (5) | |
Text
October 2, 2006 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION RE: FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION REQUEST FOR RELIEF NO. PR-02 (TAC NO. MD0284)
Dear Mr. Edington:
By letter dated February 23, 2006, supplemented by letter dated June 15, 2006, Nebraska Public Power District (the licensee) submitted Relief Request No. PR-02, related to the Fourth 10-Year Interval Inservice Inspection (ISI) Program for the Cooper Nuclear Station. In Relief Request PR-02, the licensee proposed to perform a system leakage test of Class 1 pressure retaining components in reactor coolant pressure boundary with a modified valve lineup as opposed to paragraph IWB-5222(a) of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, 2000 Edition with 2003 Addenda which requires that the pressure retaining boundary correspond to the reactor coolant boundary with all valves in the position required for normal reactor operation startup. The Nuclear Regulatory Commission (NRC) staff finds that the intent of the ASME Code is met with licensees proposed alternative.
Based on the information provided in Relief Request No. PR-02, the NRC staff concluded in the enclosed safety evaluation that the licensees compliance to the ISI Code of Record would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the staff authorizes the ISI program alternative proposed in Relief Request No. PR-02 for the fourth 10-year ISI interval for the Cooper Nuclear Station.
Sincerely,
/RA/
David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Safety Evaluation cc w/encl: See next page
October 2, 2006 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P.O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION RE: FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION REQUEST FOR RELIEF NO. PR-02 (TAC NO. MD0284)
Dear Mr. Edington:
By letter dated February 23, 2006, supplemented by letter dated June 15, 2006, Nebraska Public Power District (the licensee) submitted Relief Request No. PR-02, related to the Fourth 10-Year Interval Inservice Inspection (ISI) Program for the Cooper Nuclear Station. In Relief Request PR-02, the licensee proposed to perform a system leakage test of Class 1 pressure retaining components in reactor coolant pressure boundary with a modified valve lineup as opposed to paragraph IWB-5222(a) of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, 2000 Edition with 2003 Addenda which requires that the pressure retaining boundary correspond to the reactor coolant boundary with all valves in the position required for normal reactor operation startup. The Nuclear Regulatory Commission (NRC) staff finds that the intent of the ASME Code is met with licensees proposed alternative.
Based on the information provided in Relief Request No. PR-02, the NRC staff concluded in the enclosed safety evaluation that the licensees compliance to the ISI Code of Record would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the staff authorizes the ISI program alternative proposed in Relief Request No. PR-02 for the fourth 10-year ISI interval for the Cooper Nuclear Station.
Sincerely,
/RA/
David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
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RidsNrrPMBBenney RidsNrrLALFeizollahi Accession Number: ML062260195 OFFICE LPL4/PM LPL4/LA CFEB/BC OGC LPL4/BC NAME BBenney LFeizollahi K Gruss TCampbell DTerao DATE 8/24/06 8/24/06 9/7/06 9/18/06 9/19/06 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR RELIEF PR-02 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION
By letter dated February 23, 2006, supplemented by letter dated June 15, 2006, Nebraska Public Power District (the licensee) submitted Relief Request No. PR-02, related to the Fourth 10-Year Interval Inservice Inspection (ISI) Program for the Cooper Nuclear Station (CNS). In Relief Request PR-02, the licensee proposed to perform a system leakage test of Class 1 pressure retaining components in reactor coolant pressure boundary with a modified valve lineup that does not correspond to paragraph IWB-5222(a) of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, 2000 Edition with 2003 Addenda which requires that the pressure retaining boundary correspond to the reactor coolant boundary with all valves in the position required for normal reactor operation startup. The Nuclear Regulatory Commission (NRC) staff finds that the intent of the ASME Code is met with the licensees proposed alternative. The licensees request for relief is based on hardship of making entries into the drywell for VT-2 visual examination with the valve lineup corresponding to normal reactor operation would expose personnel to high radiation and temperature. The NRC staff has evaluated the licensees request for relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(ii) and determined that compliance to the Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
2.0 REGULATORY EVALUATION
Section 50.55a(g) of 10 CFR requires that ISI of ASME Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASME Code and applicable addenda, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). According to 10 CFR 50.55a(a)(3), alternatives to the requirements of section 50.55a(g) may be used, when authorized by the NRC, if an applicant demonstrates that the proposed alternatives would provide an acceptable level of quality and safety or if the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection (ISI) of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that ISI of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI Code of Record for the fourth 10-year inspection interval for CNS is the 2001 Edition through the 2003 Addenda of the ASME Code,Section XI.
3.0 BACKGROUND
DISCUSSION System/Component(s) for which Relief is Requested Reactor Coolant Pressure Boundary Components ASME Code Requirements The 2001 Edition through the 2003 Addenda of ASME Code,Section XI, Paragraph IWB-5222, Boundaries states that:
(a)
The pressure retaining boundary during the system leakage test shall correspond to the reactor coolant boundary, with all valves in the position required for normal reactor operation startup. The visual examination shall, however, extend to and include the second closed valve at the boundary extremity.
(b)
The pressure retaining boundary during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1pressure retaining components within the system boundary.
Table IWB-2500-1, Category B-P, Note 2, requires that the system leakage test be conducted prior to plant startup following a refueling outage.
Licensees Request for Relief Relief is requested from performing the system leakage test in accordance with the boundary requirements of the 2001 Edition of the ASME Code, 2003 Addenda, Subsection IWB-5222(a) for the portion of the ASME Code Class 1 reactor coolant boundary.
Licensees Basis for Requesting Relief Pursuant to 10 CFR 50.55a, Codes and Standards, Section (a)(3)(ii), relief is requested from the requirements of ASME Code,Section XI, for performing a system leakage test using the boundaries stated in paragraph IWB-5222(a) because performing the pressure test with this boundary would result in a hardship without a compensating increase in quality and safety due to excessive radiation exposure and personnel safety concerns (temperature levels in the drywell).
Licensees Proposed Alternative In lieu of a system leakage test during reactor startup as required by IWB-5222(a), a system pressure test is performed at the pressure associated with 100% rated reactor power.
a)
The outboard feedwater check valves, the high pressure coolant injection (HPCI) and the reactor core isolation cooling (RCIC) injection check valves are the Class 1 boundary valves and are closed for the test. The feedwater check valves are normally open for reactor startup. The inboard check valve (FW-CV-16CV) on one feedwater line is kept open by the reactor water cleanup (RWCU) flow. The RWCU system is kept in service during the pressure tests. Thus the outboard feedwater check valve and the RCIC injection check valve on this line will be pressurized during this test. The portion of piping between the other two feedwater check valves including the HPCI injection line will not be pressurized.
b)
The four outboard main steam isolation valves (MSIV) will be closed for the system pressure test and the ten-year system pressure test
[IWB-5222(b)]. The inboard MSIVs are opened to pressurize the system to the outboard valves. Both main steam drain valves are open for pressure control.
The outboard valves are the Class 1 boundary valves.
c)
Both HPCI and both RCIC steam supply valves will be closed for the system pressure test following a refueling outage. These valves close automatically on low steam supply pressure. During the ten-year system pressure test [IWB-5222(b)], the system will be pressurized to the outboard valves. The outboard valves are the Class 1 boundary valves.
4.0 TECHNICAL EVALUATION
The ASME Code,Section XI of Record requires that all Class 1 components within the reactor coolant system (RCS) boundary undergo a system leakage test at the end of each refueling outage and a system hydrostatic test at or near the end of each inspection interval. In Relief Request No. PR-02, the licensee proposed an alternative to the ASME Code system pressure test. The licensee proposes to perform a VT-2 visual examination during system leakage test at a pressure not less than that associated with 100 percent rated power and with systems in their normal lineup to the extent practical, extending to the outermost valves in those systems.
Paragraph IWB-5221(a) requires that system leakage tests be performed at a test pressure not less than the nominal operating pressure associated with 100 percent rated reactor power. To obtain nominal operating pressure for CNS with all valves in the position for normal reactor operation, the reactor must achieve 100 percent power. However, 10 CFR Part 50, Appendix G, requires that pressure tests and leak tests of the reactor vessel that are required by Section XI of the ASME Code must be completed before the core is critical. The staff determined that performance of a system leakage test at a pressure corresponding to 100 percent power for the reactor coolant boundary with valve configuration for normal reactor operation startup would amount to a major test effort requiring installation of jumpers and provision for an external pressurization source for certain systems. The staff believes that the conduct of such an operation will expose the test crew to high levels of radiation and the compliance to IWB-5222(a) would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
As an alternative, the licensee has proposed a valve configuration with pressurization of the RCS boundary by RWCU which encompasses the ASME Code-required pressure retaining boundary during system leakage test on a best effort. The licensee would perform a VT-2 visual examination of the ASME Code-required pressure boundary during the system leakage test. The NRC staff has determined that the intent of the ASME Code as stated under IWB-5222 Boundaries would be met with the licensees proposed alternative and at the same time, would provide a reasonable assurance of operational readiness.
5.0 CONCLUSION
Based on the NRC staffs evaluation of the request for relief, the licensees proposed alternative provides reasonable assurance of operational readiness, and compliance with the ASME Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the proposed alternative in Relief Request No. PR-02 is authorized for the fourth 10-year ISI interval of Cooper Nuclear Station. All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested remain applicable, including a third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: P. Patniak Date: October 2, 2006
February 2006 Cooper Nuclear Station cc:
Mr. William J. Fehrman 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. Paul V. Fleming 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 Mr. H. Floyd Gilzow 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 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 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 Mr. Daniel K. McGhee 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 P.O. Box 570 Jefferson City, MO 65102 Jerry C. Roberts, 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