ML20237A103
| ML20237A103 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/06/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS980118, NUDOCS 9808130100 | |
| Download: ML20237A103 (5) | |
Text
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N Nebraska Public Power District Nebraska's Energy Leader NLS980ll8 August 6,1998 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Containment Inspection Program Relief Requests Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46 Reference 1: Letter to USNRC Document Control Desk from J. H. Swailes (NPPD) dated February 24,1998 " Containment Inspection Program" 2: Letter to G. R. Horn (NPPD) from J. R. Hall (USNRC) dated June 30,1998,
" Request for Additional Information Related to Requests for Relief From Certain ASME Code Requirements for Inservice Inspection for Cooper Nuclear Station (TAC No. MA1163)"
In February 1998, Nebraska Public Power District (The District) submitted relief requests for the Containment Inspection Program (Reference !). The NRC requested additional information (Reference 2) on certain of these relief requests. Attachment 1 to this letter provides the additionalinformation requested.
If you have any questions regarding this submittal, please call.
Sincerely,
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Cooper Nudear Station PO. Box 98/ Brownville. NC 68321D098 Telephone: (40?) 825-3811/ Fax: (407) 825 s?H httpf/www nppd. corn
s NLS980118 August 6,1998 Par ' of 2 cc.
Regicual Administrator USNRC - Region IV -
Senior Project Manager USNRC-NRR Project Dir/ctorate Senior Resident Inspector USNRC
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Attachment I
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to NLS980118 Page 1 of 2 Resnonse to Request for Additional Informatii Cooper Nuclear Station Containment Insnection Procram Question 1.
In the Basisfor ReliefRequest No. RC-01, you state that the NDEpersonnel are quahfied and certified in accordance with a written practice based on ASNTSNT-TC-1A,1984 Edition, and not using ANSI /ASNT CP-189. Inclusion ofCP-189 in the 1992 Edition and later Editions and Addenda ofthe Code suggests that it is an experience-based improvement over the SNT-TC-1A. Also, it is a consensus (ANSI) standard.
(a)
Provide yourplans to implement Subarticle IWA-2300 (1992 Edition and Addenda)for quahfying NDEpersonnelfor all the ASME Section XI components and containment inparticular.
(b)
Explain how the use ofSNT-TC-1Afor visual examinations satisfies the standardsfor visual acuity given in Table IWA-2322-1 ofIWA-2320.
Response
(a)
The Third Ten-year Inservice Inspection (ISI) interval began on March 1, 1996. The ISI program complies with the 1989 Edition of ASME XI wbich invokes SNT-TC-1 A,1984 Edition. At the end of the interval, circa 2006, the District will update the ISI program to the latest edition of ASME XI approved by the Commission. At that time the District will also upgrade our written practice to be comparable to CP-189 for all required ASME XI visual examinations. The requirements of the Code, including CP-189, will be invoked on the NDE contractor (s).
(b)
If the relief request is approved, visual acuity will be demonstrated in accordance with IWA-2321 of the 1989 Edition of ASME XI. This is the method currently used for demon.strating the visual acuity of visual inspectors as well as NDE personnel.
Question 2.
In the Basisfor ReliefRequest No. RC-03, you state that neitherpaint nor coatings contribute to the structural integrity or leak tightness ofthe containment and that the adequacy ofappliedpaintings is veri lled through the CNS Primary Containment Maintenance Paintingprocedure. With respect to the CNS coating j
program, provide thefollowing information related to the Service Level I coating
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(i.e., protective coating @) usedinside the containment):
Standards, procedures, or guidelines usedfor: (1) surface preparation, application, surveillance and maintenance activitiesforprotective coatings, and (2) documenting the quality and condition ofreapplied; aint.
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Attachment I to NLS980118 Page 2 of 2
Response
The NRC has recently issued Generic Letter 98-04, " Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System After a Loss-of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment." The District is developing a new Coatings Program that will address the application of safety related coatings.
i A summary description of the coatings program will be provided in response to the Generic Letter. The District hereby withdraws relief request RC-03.
Question 3.
RC-04 requests reheffrom the reymrements ofBl'E-2420(b) and (c), related to successive examinations. The request does not provide any discussion of quahty and safety when theflaws and degradation areas are accepted by engineering analysis (DVE-3122.3). Discussyour plansfor monitoring the progression of the flaws and degrachnion areas wheu they are accepted by engineering analysis.
Response
The District is only requesting relief from the requirement to reinspect flaws or areas cf degradation that have been repaired or replaced in accordance with IWE-3122.2 and 3122.3. These paragraphs do not refer to IWE-2420. The requirement to reexamine the area containing flaws or degradation accepted by engineering evaluation in IWE-3122.4(b) still applies.
Question 4.
IVith respect to Reliefrequest No. RC-05 related to bolted connections, explain how thepreload, and the condition of the boks ofpressure-unseating containment penetrations are monitored and maintained. Provide a list of such penetrations in the CNS contamment and the procedures used to monitor and maintain the functionality of their hohs.
Response
Upon flirther review, the District has concluded that reliefis not required at this time. If the District determines that monitoring preload for bolted primary containment connections is impractical for specific penetrations, a relief request will be resubmitted at that time. The District hereby withdraws relief request RC-05.
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ATTACHMENT 3 LIST OF NRC COMMITMENTS 4
I Correspondence No:,,JLS980118 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended cr planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments.
Please notify the NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments COMMITMENT OR OUTAGE None N/A l
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