ML20129E615

Forwards RAI Re Third 10-yr Interval ISI Program for Plant in Order to Complete Review

ML20129E615
Person / Time
Site:	Cooper
Issue date:	10/24/1996
From:	Hall J NRC (Affiliation Not Assigned)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
References
TAC-M94000, NUDOCS 9610280113
Download: ML20129E615 (7)

Text

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9 ' Mi b O U00 4, 4 UNITED STATES j .j

't NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20566-0001 1

i ***** October 24, 1996 Mr. G. R. Horn Sr. Vice President of Energy Supply Nebraska Public Power District

' 1414 15th Street Columbus, NE 68601

SUBJECT:

COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) PROGRAM (TAC NO. M94000)

Dear Mr. Horn:

By letter dated October 18, 1995, the Nebraska Public Power District (NPPD)

, submitted the Third 10-Year Interval ISI Program for the Cooper Nuclear Station (CNS) for NRC review and approval, in accordance with the requirements of 10 CFR 50.55a. By letter dated April 11, 1996, NPPD submitted Revision 1 to the Third 10-Year Interval ISI Program for CNS, in response to the staff's request for additional information (RAI), dated February 8,1996. This revision included some new and some revised relief requests. By letter dated August 5, 1996, NPPD provided additional information in response to the staff's RAI dated June 3, 1996.

The NRC staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory, has continued to review and evaluate the information provided in the above submittals. Based upon that ongoing review, the staff will require additional information in order to complete its review

of the Third 10-year Interval ISI Program for CNS. The staff's current request for additional information is attached. In order for the staff to complete its review in a timely manner, we request that you submit a response to the attached RAI within 60 days of the receipt of this letter. In addition, to expedite our review, please send a copy of your response to

Michael T. Anderson INEL Research Center 2151 North Boulevard P. O. Box 1625 Idaho Falls, Idaho 83415-2209

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t Mr. G. R. Horn If you have any questions regarding this request, please call me at  ;

(301) 415-1336.

I Sincerely, i fysl .

a s R. Hall, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosure:

Request For Additional Information l cc w/ enc 1: See next page i

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Mr. G. R. Horn If you have any questions regarding this request, please call me at (301) 415-1336.

Sincerely, ORIGINAL SIGNED BY: i James R. Hall, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-298 I

Enclosure:

Request For Additional Information cc w/ encl: See next page i

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o Mr. G. R. Horn Nebraska Public Power Company Cooper Nuclear Station l .cc:

Mr. John R McPhail, General Counsel Lincoln Electric System Nebraska Public Power District ATTN: Mr. Ron Stoddard P. O. Box 499 11th & 0 Streets Columbus, NE 68602-0499 Lincoln, NE 68508 Nebraska Public Power District Midwest Power ATTN: Mr. P. D. Graham ATTN: Richard J. Singer, Manager-Nuclear Vice President of Nuclear Energy 907 Walnut Street P. O. Box 98 P. O. Box 657 Brownville, NE 68321 Des Moines, IA 50303 Randolph Wood, Director Nebraska Department of Environmental Nebraska Public Power District Control ATTN: Mr. B. L. Houston, Nuclear P. O. Box 98922 Licensing & Safety Manager l Lincoln, NE 68509-8922 P. O. Box 98 i Brownville, NE 68321 1 Mr. Larry Bohlken, Chairman  !

Nemaha County Board of Commissioners 1 Nemaha County Courthouse 1824 N Street Auburn, NE 68305 l 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 1000 '

Arlington, TX 76011 Ms. Cheryl Rogers, LLRW Program Manager Division of Radiological Health Nebraska Department of Health 301 Centennial Mall, South P. O. Box 95007 Lincoln, NE 68509-5007 Mr. Ronald A. Kucera, Department Director of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102

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i, REQUEST FOR ADDITIONAL INFORMATION f THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM r

NEBRASKA PUBLIC POWER DISTRICT

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l COOPER NUCLEAR STATION DOCKET NO. 50-298 i

On October 18, 1995, the Nebraska Public Power District (NPPD) submitted the i Third 10-year Interval Inservice Inspection (ISI) Program for the Cooper i Nuclear Station (CNS), By letter dated April 11, 1996, NPPD submitted j Revision 1 to the third 10-year interval ISI program for CNS, in response to the staff's request for additional information (RAI), dated February 8,1996.

This revision included some new and some revised relief requests. By letter i dated August 5,1996, NPPD provided additional information in response to the i staff's RAI dated June 3, 1996. The staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory (INEL), has continued to

', review and evaluate the information provided in those submittals. Based upon

that ongoing review, the staff requires the additional information discussed below, in order to complete its review of the CNS third 10-year interval ISI program.

1. Scone / Status of Review l

I Throughout the service life of a water-cooled nuclear power facility, l 10 CFR 50.55a(g)(4) requires that components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Boiler.

and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in ASME Code Section XI, Rules for l 4 Inservice Inspection of Nuclear Power Plant Components", to the extent practical within the limitations of design, geometry, and materials of

, construction of the components. This section of the regulations also i requires that inservice examinations of components and system pressure

tests conducted during the successive 120-month inspection interval comply with the requirements in the latest edition and addenda of the Code incorporated by. reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of a successive 120-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and i addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein, i The licensee, Nebraska Public Power District, has prepared the Cooper

Nuclear Station, Third 10-Year Interval ISI Program Plan to meet the requirements of the 1989 Edition of Section XI of the ASME Code, i ENCLOSURE 1

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As required by 10 CFR 50.55a(g)(5), if the licensee determines that certain Code examination requirements are impractical and requests relief, the licensee shall submit information to the Nuclear Regulatory Commission (NRC) to support that determination.

The staff has reviewed the information in the Cooper Nuclear Station, Third 10-Year Interval ISI Progran Plan, submitted by letter dated October 18, 1995, as revised by letter dated April 11, 1996, and the requests for relief from the ASME Code Section XI requirements that the licensee has determined to be impractical.

2. Additional Information Reauired Based on the above review, the staff has concluded that additional information and/or clarification is required to complete the review of the CNS ISI Program Plan.

A. In accordance with 10 CFR 50.55a(c)(3), 10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2), ASME Code cases may be used as alternatives to Code requirementr. Code cases that the NRC has approved for use are listed in Reguiatory Guide 1.147, Inservice Inspection Code Case Acceptability, with any additional conditions the NRC may have imposed. When used, these Code cases must be implemented in their entirety. Published Code cases awaiting approval and subsequent listing in Regulatory Guide 1.147 may be adopted only if the licensee requests, and the NRC authorizes, their use on a case-by-case basis.

For Code cases awaiting NRC approval, use of alternatives to Code requirements may be acceptable when licensees adopt conditions deemed appropriate by the NRC staff. As such, a licensee proposing the use of a Code case not yet approved by the staff must commit to certain conditions, as specified, in order for the staff to find the alternative acceptable.

a) In Request for Relief RI-14, Nebraska Public Power District has requested to implement the alternative to Code requirements contained in Code Case N-509, Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments.

The NRC staff's position is that this alternative to the Code requirements is acceptable for use with the following condition:

that the licensee perform a minimum 10% sample examination of all integrally welded attachments for each Examination Category Item in each Code class per interval.

b) In Request for Relief PR-05, Nebraska Public Power District has requested to implement the alternative to Code requirements contained in Code Case N-522, Pressure Testing of Containment Penetration Piping. The NRC staff's position is that the use of Code Case N-522 is acceptable with the following conditions: the test is conducted at the peak calculated containment pressure, and

I the test procedure permits the detection and location of through-wall leakage in containment isolation valves (CIVs) and pipe i segments between the CIVs.

i l c) In Request for Relief RI-02, Nebraska Public Power District requested authorization to continue using existing calibration

, blocks. For the existing calibration blocks, the licensee has committed to perform a comparison between the attenuation of the i calibration block and the material being examined when the

calibration block lacks appropriate documentation. The staff's position is that the proposed alternative must also include the performance of material velocity checks of the calibration blocks in

, conjunction with the attenuation checks. This will ensure that the ultrasonic scanning angle in the materials is essentially the same.

' In order to complete the review of the licensee's submittal for use of the proposed alternatives to Code requirements, a docketed commitment to comply with the subject conditions is necessary in order for the staff to 4 i authorize the alternatives.

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B. Based on a review of the response to the request for additional -l information subraitted by Nebraska Public Power District by letter dated '

August 5, 1995, the following clarification is required.

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a) In the licensee's response to the staff's questions regarding Re pest for Relief PR-02, the licensee stated that the pressure test

bcu.edaries are essentially equivalent to the Code-required pressure

]' boundaries. Provide a list of the portions of all Class 1 pressure  !

test boundaries excluded from the system leakage and hydrostatic tests. Describe how the pressure test requirements will be l

satisfied for those remaining sections of piping beyond the proposed j boundaries.

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b) Describe how the proposed alternative will provide the same level of

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quality and safety for the pressure test boundaries defined by the Code.

c) Describe how a test pressure associated with 100% reactor pressure will be achieved.

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