ML20069N341
| ML20069N341 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/17/1994 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NSD940545, NUDOCS 9406220349 | |
| Download: ML20069N341 (2) | |
Text
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NSD940545 June 17,1994 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Subject:
10 CFR 50, Appendix J; Expansion Bellows Testing Requirements Cooper Nuclear Station NRC Docket No. 50-298, License No. DPR-46 The Nebraska Public Power District (District) has recently initiated a design basis reconstitution effort for the primary containment at Cooper Nuclear Station (CNS). During this effort, the expansion bellows associated with the vent system connecting the drywell and the preswre suppression pool were evaluated to determine if they are subject to Type B, local Lesk Rate Test (LLRT) requirements, as delineated in 10 CFR 50, Appendix J, Section H.G.J. These expansion be'iows (eight in total; one for each vent pipe) are an integral part of the Mark I containment at CNS. These bellows are single-ply and are currently not locally leak rate testable. These bellows are welded at each end directly into the pipe; there are no bolts, seals, or gaskets.
10 CFR 50, Appendix J, Section II.G.1 requires Type B LLRTs for containment penetrations whose design incorporates resilient seals, gaskets, or scalant compounds, piping penetrations i
fitted with expansion bellows, and electrical penetrations fitted with flexible metal seal assemblies. The District has determined that the subject expansion bellows do not fall within the bounds of this requirement and, therefore, do not require Type B LLRTs.
This determination is based on the District's interpretation that the bellows are an integral part of the primary containment liner, as opposed to being classified as part of a primary containment penetration. Being part of the primary containment liner, these bellows are sub,lected to Type A Integrated 1.cak Rate Tests (ILRTs) per the requirements of 10 CFR 50, Appendix J. Because of the bellows design, the Type A tests provide a valid indication of the bellows' leak-tightness.
Our position and reasoning on this matter has been discussed with the NRC staff and the District is submitting this letter for informational pmposes. Should the NRC's position on the Appendix J testing requirements of the subject bellows be different from the District's, please advise.
Sine rety, Horn
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' 'U.S. Nuclear Regulatory Commission June 17,1994 Page 2 of 2 4
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- 11. R. llorchert Department of ifcalth State of Nebraska NRC Regional Office Region IV Arlington, TX NRC Resident Inspector Cooper Nuclear Station e
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