ML20212E068

Forwards SE Re Evaluation of Third 10-yr Interval Insp Program Plan & Associated Requests for Relief for Plant. Inel Technical Ltr Rept Also Encl

ML20212E068
Person / Time
Site:	Cooper
Issue date:	10/23/1997
From:	Clifford J NRC (Affiliation Not Assigned)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
Shared Package
ML20212E074	List: L-96-034, TER on Third 10-Yr Interval ISI Program Plan:Nppd Cns ML20212E068 ML20212E081
References
TAC-M94000, NUDOCS 9711030044
Download: ML20212E068 (4)

Text

1 Co - 718

. * ,%g y- 4 UNITED STATES

, g

,j NUCLEAR REGULATORY COMMISSION WAaHINGToN, D.C. SOMH001

\*****/ October 23, 1997 Mr. G. R. Horn Sr. Vice President of Energy Supply

. Nebraska Public Power District 1414 15th Street Columbus, NE 68601

SUBJECT:

EVALUATION OF THE THIRD TEN-YEAR IlJERVAL INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF FOR COOPER NUCLEAR STATION (TAC NO. M94000)

Dear Mr. Horn:

By letter dated Octob2r 18, 1995, the Nebraska Public Power District (NPPD) submitted the Third 10-Year Inservice Inspection [ISI) Program Plan for the Cooper Nuclear Station (CNS). NPPD submitted Rev'sion 1 to its ISI program plan by letter dated April 11, 1996. In your letters, you requested relief from certain requirements in Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. You provided additional information in letters dated August 5, 1996, and February 7, 1997.

The staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory (INEL), has completed its review of the information provided in support of Requests for Relief Nos. RI-01, -02, -03, RI-05 through RI-24, and PR-01 through PR-09. RI-13 and RI-19, which were evaluated separately by the staff, were authorized through the end of the third'10-year interval by letters dated February 27, and June 7, 1996, respectively. RI-23 was withdrawn by the licensee in the August 5,1996, letter. RI-01, previously submitted by NPPD's letter dated July 21, 1995, was withdrawn in the October 18, 1995 submittal. The results of our review are documented in the enclosed safety evaluation (Enclosure 1).

The staff conclu' des that Requests for Relief RI-05, RI-15, RI-18, RI-20, Revision 1, RI-21, and RI-22 demonstrate that the related ASME,Section XI requirements are impractical, and that the proposed alternatives provide reasonable assurance of operational readiness of the subject components.

4 Therefore, the staff concludes that these requests for relief are granted pursuant to 10 CFR 50.55a(g)(6)(1). .

The staff concludes that for Requests for Relief RI-02, Revision 1. RI-03, RI-07, RI-08, RI-10, RI-12, RI-14 RI-16, PR-01, PR-02, PR-03, Revision 1 PR-04, PR-05, PR-06, PR-07, PR-08, and PR-09: (1) the licensee's proposed alternatives provide-an acceptable level of quality and safety; or (2) Code compliance will result in hardship or unusual difficulty without a compensating increase in quality and safety. Therefore, the staff concludes that the alternatives contained in these reliefs are authorized pursuant to 10 CFR 50.55a(a)(3)(1) or 10 CFR 50.55a(a)(3)(ii).

[TJP?an Fd8llp f3R0 RLE CENTER C 1

(/ d u d b _O h\ g

,lllIl(ll.l,I!,L,ll

Mr. G. R. Horn October 23, 1997 The staff also concludtd that for Requests for Relief RI-06 Revision 1 RI-09, RI-ll, RI-17, and RI-24, the licensee did not provide sufficient justification to support the determination that the Code requirements are impractical, nor that to comply with Code requirements would result in a hardship. Therefore, the staff has denied these relief requests. The technical bases for these denials is discussed in the enclosed safety

evaluation.

I With regard to Request for Relief No. RI-13, the staff noted that your l Improved Technical Specification (ITS) conversion submittal dated March 27, '

1997, proposed to relocate the requirements for visual and functional testing of snubbers to the Technical Requirements Manual (TRM). The relocation matrix included with your ITS submittal indicated that changes to the TRM would be controlled pursuant to 10 CFR 50.59. This could potentially permit changes to the snubber testing program without the same level of staff review that would occur for changes to Technical S)ecifications or to the ISI program under 10 CFR 50.55a. Therefore, you s1ould reevaluate the basis for this relief request in conjunction with the proposed ITS conversion and submit a revised '

relief request as appropriate.

A co)y of.INEL's Technical Evaluation Report is provided as Enclosure 2. If you lave any questions, please contact Mr. James R. Hall at (301) 415-1336.

i Sincerely,

? Orig, signed by David L. Wigginton for James W. Clifford,. Acting Director Project Directorate IV-1 Division of Resctor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Safety Evaluation Report

2. INEL Technical Letter ' Report cc w/encis: See next page DISTRIBUTION:

Docket File PUBLIC PD4-1 r/f J. Hall ACRS G. Hill (2)

E. Adensam OGC (15B18) T. Gwynn, RIV J. Clifford(EGAl) T. McLellan (TKH) T. Hiltz, EDO C. Hawes Document Name: T. Harris (SE C0094000.LTR *Seeonly)ious prev concurrence 0, 1 ,

0FC PM/PD4-1 LA/PD4-1 OGC: (A)DNQNkcCk NAME JHall/vw CHawes 011tfl MYoung* JClifford DATE /c /M/97 JD/8 /97 08/26/97 /'d /17/97 COPY ffEji/NO YES/NO YES/N0 YES/i@

OFFICLAL RECORD COPY

Mr. G. R. Horn .

included with your ITS submittal indicated that changes to the TRM would be controlled pursuant to 10 CFR 50.59. This could potentially permit changes to the snubber testing program without the same level of staff review that would occur for changes to Technical 5)ecifications or to the ISI program under 10 CFR 50.55a. Therefore, you s1ould reevaluate the basis for this relief request in conjunction with the proposed ITS conversion and submit a revised relief request as appropriate.

A cosy of INEL's Technical Evaluation Report is provided as Enclosure 2. If you save any questions, please contact Mr. James R. Hall at (301) 415-1336.

Sincerely, i

James W. Clifford, Acting Director Project Directorate IV-1 l Division of Reactor Projects III/IV l Office of Nuclear Reactor Regulation Docket No. 50-298 /

Enclosures:

1. Safety Evaluation Report

2. INEL Technical Letter Report cc w/encis: 'See next page DISTRIBUTI.QH: , /

Docket File PUBLIC JD4-1 r/f J. Roe -

ACRS / G. Hill (2)

E. Adensam (EGA1)

J. Hall OGC (15B18) / T. Gwynn, RIV T. McLellan (TKM) / M. Dapas, EDO C. Hawes T. Harris (SE only)

J. Hall /

Document Name: C0094000.LTR / ,.

)

0FC PM/PD4-1_ LA/PD4-1 / OGdN b[ D/PD4-1 NAME JHa11/v 7 CHawes / M JNN(Wy N$Y DATE 6 /Sg/97 [o /30 /97 [/h6/97

/ /97 COPY YES/NO YiIS/NO YES/[0)

~

YES/NO CIAL RECORD COPY

c

• Mr. G. R. Norn Nebraska Public Power Company Cooper Nuclear Station cc:

Mr. John R McPhail, General Counsel Lincoln Electric System Nebraska Public Power District ATTN: Mr. Ron Stoddard P. O. Box 499 lith & 0 Streets Columbus, NE 68602-0499 Li:icoln, NE 68508 Nebraska Public Power District MidAme ican Energy ATTN: Mr. P. D. Graham ATTN: Dr. William D. Leech, Manager-Nuclear Vice President of Nuclear Energy 907 Wair.ut Street P. O. Box 98 P. O. Box 657

-Brownville, NE 68321 Des Moines, IA 50303-0657 Randolah Wood, Director Nebrasca Department of Environmental Nebraska Public Power District Control. ATTN: Mr. B. L. Houston, Nuclear P. O. Box 98022 Licensing & Safety Manager Lincoln, NE 68509-8922 P. O. Box 98 Brownyt11e, NE 68321 Mr. Larry Bohlken, Chairman Nemaha County Board of. Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 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