ML19196A345

July 18, 2019 Public Teleconference Slides Appendix J Exemption Request Presubmittal Teleconference

ML19196A345
Person / Time
Site:	Cooper
Issue date:	07/18/2019
From:	Thomas Wengert Plant Licensing Branch IV
To:	Dent J Nebraska Public Power District (NPPD)
Wengert T, NRR/DORL/LPLIV, 415-4037
References
Download: ML19196A345 (13)

Text

Nebraska Public Power District Cooper Nuclear Station July 18, 2019 1

Introductions - Dave Van Der Kamp NPPD Discussion Questions Closing - Dave Van Der Kamp 2

Dave Van Der Kamp Licensing Manager 3

Tom Robinson Engineering Programs &

Components Engineer 4

Appendix J Frequency Requirements CNS TS 5.5.12 requires Appendix J Program to be in accordance with RG 1.163 RG 1.163 approves NEI 94-01 as an acceptable means of demonstrating compliance with Appendix J requirements 5

NEI 94-01 sections 10.2.1.3 and 10.2.3.3 have the following Requirements:

If penetration (type B) or valve (type C) is replaced or engineering judgement determines that modification of penetration or valve has invalidated penetration's or valve's performance history, then frequency shall be in accordance with 10.2.1.2 (type B) or 10.2.3.2 (type C).

Sections 10.2.1.2 (type B) or 10.2.3.2 (type C)

Frequency Requirements:

At least once every 30 months 6

Background

CNS design contains two RHR HX relief valves that discharge back to Torus Valves have safety function in the open (overpressurization) and closed (primary containment) positions Within scope of IST Program [10CFR50.55a] and 10CFR 50 Appendix J 7

CNS Current Practice Pretested new and/or rebuilt valve assemblies typically utilized to satisfy IST Program Historical results for Appendix J as found and as left testing on testable discharge flange and valve have been excellent 8

Current Issue Even though IST Program would allow IST testing of the RVs to be less frequent than every outage, replacing relief valves with pretested new and/or rebuilt valves causes frequency of performing Appendix J testing to be performed every outage Results in additional Appendix J testing, draining of the system, removal of the RVs, etc.

9

Process Since NEI 94-01 is endorsed by RG 1.163, is it appropriate to evaluate the alignment of App. J and IST testing frequencies as an acceptable alternative to the RG or Is an exemption request per 10 CFR 50.12 the appropriate process for aligning Appendix J testing frequency to allow it to be performed at the same frequency as IST required testing.

10

Dave Van Der Kamp Licensing Manager 11

Any further questions or comments 12

Dave Van Der Kamp Licensing Manager 13