ML16015A138
| ML16015A138 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/22/2015 |
| From: | Flaherty J Nebraska Public Power District (NPPD) |
| To: | Thomas Wengert Plant Licensing Branch IV |
| References | |
| Download: ML16015A138 (3) | |
Text
NRR-PMDAPEm Resource From: Flaherty, James R. <jrflahe@nppd.com>
Sent: Tuesday, December 22, 2015 12:50 PM To: Wengert, Thomas Cc: Shaw, Jim D.; Van Der Kamp, David W.; Barker, Troy S.; Robinson, Thomas V. [Tom]
Subject:
[External_Sender] FW: Cooper Nuclear Station - Requests for Relief RP-01 through RP-09, RV-01 through RV-05, and RG-01 Alternatives to OM Code Requirements for IST for the Fifth 10-Year Program Interval Mr. Wengert, Nebraska Public Power District agrees that the references to 10 CFR 50.5a(h)(3)(z)(1) and 10 CFR 50.55a(h)(3)(z)(2), in the Fifth 10-Year IST Program Interval submittal, are in error and the correct citation for the alternatives proposed are 10 CFR 50.55a(z)(1) and 10 CFR 50.55a(z)(2) respectively.
Jim Flaherty 402-825-5420 Mr. Shaw, Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z), proposed alternatives to the requirements of 10 CFR 50.55a paragraphs (b) through (h), may be used when authorized by the U.S. Nuclear Regulatory Commission (NRC) if the licensee demonstrates that (1) the proposed alternatives would provide an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety.
In the Subject requested dated March 19, 2015 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML15084A221), as supplemented by letters dated June 9, 2015 (ADAMS Accession No. ML15167A068) and June 30, 2015 (ADAMS Accession No. ML15188A349), Nebraska Public Power District (the licensee, NPPD) submitted requests for relief RP-01 through RP-09, RV-01 through RV-05, and RG-01 to the NRC, proposing alternatives to certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the fifth 10-year inservice testing program interval for Cooper Nuclear Station.
Specifically, the licensee proposed alternatives in RP-01 through RP-09 and RV-01 through RV-05 pursuant to 10 CFR 50.55a(h)(3)(z)(1), on the basis that the alternatives provide an acceptable level of quality and safety. The licensee also proposed an alternative in RG-01, pursuant to 10 CFR 50.55a(h)(3)(z)(2), on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.
The NRC staff notes that the licensee appears to have introduced editorial errors concerning the 10 CFR 50.55a paragraph citations in its request. The correct citation for the alternatives proposed for RP-01 through RP-09 and RV-01 through RV-05 is 10 CFR 50.55a(z)(1) and the correct citation for the alternative proposed for RG-01 is 10 CFR 50.55a(z)(2). The staff also notes that the paragraph headings and citations for these 10 CFR 50.55a sections were changed by the Federal Register (FR) notice dated November 5, 2014 (79 FR 65776), which became effective on December 5, 2014. You can find the cross reference tables to the old paragraph headings and citations, which are cited in the notice, at ADAMS Package Accession No. ML14211A050.
Given the above, the NRC staff will consider the proposed alternatives described in Relief Requests RP-01 through RP-09 and RV-01 through RV-05, to be requested pursuant to 10 CFR 50.55a(z)(1). The staff will consider the alternative described in Relief Request RG-01, to be requested pursuant to 10 CFR 50.55a(z)(2).
1
Please confirm that the NRC staffs understanding of these apparent editorial errors in your request, as described above, is correct, or provide clarification if necessary.
Tom Wengert USNRC Sr. Project Manager NRR/DORL/LPL4-2 (301) 415-4037 2
Hearing Identifier: NRR_PMDA Email Number: 2600 Mail Envelope Properties (2A6B2186150CB64FA4BDFC45E0085DD81DCF2D39)
Subject:
[External_Sender] FW: Cooper Nuclear Station - Requests for Relief RP-01 through RP-09, RV-01 through RV-05, and RG-01 Alternatives to OM Code Requirements for IST for the Fifth 10-Year Program Interval Sent Date: 12/22/2015 12:50:03 PM Received Date: 12/22/2015 12:50:17 PM From: Flaherty, James R.
Created By: jrflahe@nppd.com Recipients:
"Shaw, Jim D." <jdshaw@nppd.com>
Tracking Status: None "Van Der Kamp, David W." <dwvande@nppd.com>
Tracking Status: None "Barker, Troy S." <tsbarke@nppd.com>
Tracking Status: None "Robinson, Thomas V. [Tom]" <tvrobin@nppd.com>
Tracking Status: None "Wengert, Thomas" <Thomas.Wengert@nrc.gov>
Tracking Status: None Post Office: cgoexg41 Files Size Date & Time MESSAGE 3345 12/22/2015 12:50:17 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
NRR-PMDAPEm Resource From: Flaherty, James R. <jrflahe@nppd.com>
Sent: Tuesday, December 22, 2015 12:50 PM To: Wengert, Thomas Cc: Shaw, Jim D.; Van Der Kamp, David W.; Barker, Troy S.; Robinson, Thomas V. [Tom]
Subject:
[External_Sender] FW: Cooper Nuclear Station - Requests for Relief RP-01 through RP-09, RV-01 through RV-05, and RG-01 Alternatives to OM Code Requirements for IST for the Fifth 10-Year Program Interval Mr. Wengert, Nebraska Public Power District agrees that the references to 10 CFR 50.5a(h)(3)(z)(1) and 10 CFR 50.55a(h)(3)(z)(2), in the Fifth 10-Year IST Program Interval submittal, are in error and the correct citation for the alternatives proposed are 10 CFR 50.55a(z)(1) and 10 CFR 50.55a(z)(2) respectively.
Jim Flaherty 402-825-5420 Mr. Shaw, Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z), proposed alternatives to the requirements of 10 CFR 50.55a paragraphs (b) through (h), may be used when authorized by the U.S. Nuclear Regulatory Commission (NRC) if the licensee demonstrates that (1) the proposed alternatives would provide an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety.
In the Subject requested dated March 19, 2015 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML15084A221), as supplemented by letters dated June 9, 2015 (ADAMS Accession No. ML15167A068) and June 30, 2015 (ADAMS Accession No. ML15188A349), Nebraska Public Power District (the licensee, NPPD) submitted requests for relief RP-01 through RP-09, RV-01 through RV-05, and RG-01 to the NRC, proposing alternatives to certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the fifth 10-year inservice testing program interval for Cooper Nuclear Station.
Specifically, the licensee proposed alternatives in RP-01 through RP-09 and RV-01 through RV-05 pursuant to 10 CFR 50.55a(h)(3)(z)(1), on the basis that the alternatives provide an acceptable level of quality and safety. The licensee also proposed an alternative in RG-01, pursuant to 10 CFR 50.55a(h)(3)(z)(2), on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.
The NRC staff notes that the licensee appears to have introduced editorial errors concerning the 10 CFR 50.55a paragraph citations in its request. The correct citation for the alternatives proposed for RP-01 through RP-09 and RV-01 through RV-05 is 10 CFR 50.55a(z)(1) and the correct citation for the alternative proposed for RG-01 is 10 CFR 50.55a(z)(2). The staff also notes that the paragraph headings and citations for these 10 CFR 50.55a sections were changed by the Federal Register (FR) notice dated November 5, 2014 (79 FR 65776), which became effective on December 5, 2014. You can find the cross reference tables to the old paragraph headings and citations, which are cited in the notice, at ADAMS Package Accession No. ML14211A050.
Given the above, the NRC staff will consider the proposed alternatives described in Relief Requests RP-01 through RP-09 and RV-01 through RV-05, to be requested pursuant to 10 CFR 50.55a(z)(1). The staff will consider the alternative described in Relief Request RG-01, to be requested pursuant to 10 CFR 50.55a(z)(2).
1
Please confirm that the NRC staffs understanding of these apparent editorial errors in your request, as described above, is correct, or provide clarification if necessary.
Tom Wengert USNRC Sr. Project Manager NRR/DORL/LPL4-2 (301) 415-4037 2
Hearing Identifier: NRR_PMDA Email Number: 2600 Mail Envelope Properties (2A6B2186150CB64FA4BDFC45E0085DD81DCF2D39)
Subject:
[External_Sender] FW: Cooper Nuclear Station - Requests for Relief RP-01 through RP-09, RV-01 through RV-05, and RG-01 Alternatives to OM Code Requirements for IST for the Fifth 10-Year Program Interval Sent Date: 12/22/2015 12:50:03 PM Received Date: 12/22/2015 12:50:17 PM From: Flaherty, James R.
Created By: jrflahe@nppd.com Recipients:
"Shaw, Jim D." <jdshaw@nppd.com>
Tracking Status: None "Van Der Kamp, David W." <dwvande@nppd.com>
Tracking Status: None "Barker, Troy S." <tsbarke@nppd.com>
Tracking Status: None "Robinson, Thomas V. [Tom]" <tvrobin@nppd.com>
Tracking Status: None "Wengert, Thomas" <Thomas.Wengert@nrc.gov>
Tracking Status: None Post Office: cgoexg41 Files Size Date & Time MESSAGE 3345 12/22/2015 12:50:17 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received: