ML120270155

Request for Additional Information, Relief Request No. RV-01, Revision 1, HPCI Solenoid Operated Drain Valve Testing, Fourth 10-Year Inservice Testing Program Interval

ML120270155
Person / Time
Site:	Cooper
Issue date:	02/13/2012
From:	Lynnea Wilkins Plant Licensing Branch IV
To:	O'Grady B Nebraska Public Power District (NPPD)
Wilkins, L E, NRR/DORL/LPL4, 415-1377
References
TAC ME7021
Download: ML120270155 (5)

Text

lINITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 13, 2012 Mr. Brian J. O'Grady Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST FOR RELIEF FOR THE FOURTH 10-YEAR PUMP AND VALVE INSERVICE TESTING PROGRAM (TAC NO. ME7021)

Dear Mr. O'Grady:

By letter dated August 24, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11242A129), Nebraska Public Power District (NPPD, the licensee) submitted requests for relief (RV-07, Revision 0, and RV-01, Revision 1) from certain inservice testing (1ST) American Society of Mechanical Engineers Boiler and Pressure Vessel Code (Code) requirements for Cooper Nuclear Station pursuant to Section 50.55a of Title 10 of the Code of Federal Regulations. These requests are applicable to the fourth 10-year 1ST interval, which began March 1, 2006, and request relief from certain 1ST Code requirements regarding the required 2-year test interval for pressure isolation valve leakage rate testing and the frequency for disassembly and examination of the affected components.

The U.S. Nuclear Regulatory Commission staff has reviewed your submittal and determined that additional information is needed for the staff to complete its evaluation. The RAI was transmitted via e-mail toMr.EdwardMcCutchenofyourstaffonJanuary13.2012.Mr.

McCutchen indicated via telephone on January 26,2011, that the response would be provided within 30 days of receipt of this letter.

B. O'Grady -2 If you have any questions, please contact me at 301-415-1377 or via e-mail at Lynnea.wilkins@nrc.gov.

Sincerely,

~ Lynnea E. Wilkins, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 By letter dated August 24, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11242A129), Nebraska Public Power District (NPPD, the licensee) submitted requests for relief (RV-07, Revision 0, and RV-01, Revision 1) from certain inservice testing (1ST) requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (Code), for Cooper Nuclear Station (CNS), pursuant to Section 50.55a of Title 10 of the Code of Federal Regulations. These requests are applicable to the fourth 10 year 1ST interval, which began March 1, 2006, and request relief from certain 1ST Code requirements regarding the required 2-year test interval for pressure isolation valve leakage rate testing and the frequency for disassembly and examination of the affected components.

The U.S. Nuclear Regulatory Commission staff has reviewed and evaluated the information provided by the licensee and has determined that the following information is needed in order to complete its review.

1. Please describe how NPPD is meeting the requirements of ISTC-3530, "Valve Obturator Movement," ISTC-5151, "Solenoid-Operated Valves (SOVs) - Valve Stroke Testing,"

ISTC-5152, "SOVs - Stroke Test Acceptance Criteria," and ISTC-5153, "SOVs - Stroke Test Corrective Action," at CNS. Please state if NPPD also needs relief from these requirements based on this request.

2. For this relief request, NPPD requested relief from ISTC-3510, "Exercising Test Frequency." NPPD stated in the August 24, 2011, request that it will exercise each valve to the full closed position on a quarterly basis, which is equivalent to the "nominally every 3 month" requirement of ISTC-3510. Please describe in greater detail the basis for NPPD's request for relief from ISTC-3510 since, it appears that NPPD can meet the requirement.

3. Please provide any additional operational history (maintenance and reliability data) for valves similar to high-pressure coolant injection (HPCI)-SOV-SSV64 and HPCI-SOV SSV87 at CNS that can demonstrate greater reliability of these valves for time periods longer than the four maintenance cycles stated in this request.

4. Please discuss the consequences of HPCI-SOV-SSV64 and HPCI-SOV-SSV87 failure during normal and emergency operations.

5. The August 24, 2011 submittal provides risk information but does not indicate that this is a risk-informed application consistent with Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and RG 1.175, "An Approach for Plant Specific Risk-Enclosure

-2 Informed Decision Making Inservice Testing." The staff does not typically consider risk information that does not address RG 1.174 and RG 1.175. Please confirm that this submittal is not intended to be risk-informed or provide information consistent with RG 1.174, RG 1.175, and RG 1.200, Revision 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk Informed Activities."

ML120270155 *via memo dated OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DE/EPTB/BC NRR/LPL4/BC NRRlLPL4/PM NAME LWilkins JBurkhardt AMcMurtray* MMarkley LWilkins DATE 1/30/12 1/30/12 12/19/11 12/10/12 2113/12