ML20237C436

Forwards RAI Re Request for Relief RI-13,RI-17 & RI-25 Related to Third 10-yr Interval ISI Program for Cooper Nuclear Station.Response Requested within 30 Days of Receipt of Ltr

ML20237C436
Person / Time
Site:	Cooper
Issue date:	08/14/1998
From:	Hall J NRC (Affiliation Not Assigned)
To:	Horn G NEBRASKA PUBLIC POWER DISTRICT
References
TAC-MA2138, NUDOCS 9808210165
Download: ML20237C436 (5)

Text

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Mr. G. R. Horn ~ .

_. August 14, 1998' .

., Sr. Vice Presidant of En:rgy Supply Nebraska Public Power District I 141415th Street  !

Columbus, NE 68601 l

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING COOPER l l NUCl. EAR STATION THIRD INTERVAL INSERVICE INSPECTION PROGRAM l PLAN REQUESTS FOR RELIEF (TAC NO. MA2138)

Dear Mr. Horn:

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By letter dated April 23, .1998, the Nebreska Public Power District submitted several requests for relief related to the third 10-year interval inservice Inspection Program for the Cooper Nuclear Station. Based on our ongoing review of these relief requests (RI-13, RI-17, and Rl-25), the l staff has developed the enclosed request for additional information (RAI).

You are requested to provide a response to the enclosed RAI within 30 days of the recebt of this letter. In addition, to expedite the review process, please send a copy of the your response

,_ . to the NRC's contractor, INEEL, at the following address:

MichaelT. Anderson INEEL Research Center 2151 North Boulevard l

P.O. Box 1625 j idaho Falls, Idaho 83415-2209 {

if there are any questions concerning the RAI, please contact me at (301) 415-1336.

Sincerely,  !

I l ORIGINAL SIGNED BY: D. Wigginton for l ;

James R. Hall, Senior Project Manager i Project Directorate IV-1 l Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation l Docket No. 50-298 l

Enclosure:

Request for Additional Information l-cc w/ encl: See next page DISTRIBUTION:

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 3066db.0001

'+,***** ,o August 14, 1998 Mr. G. R. Hom Sr. Vice President of Energy Supply Nebraska Public Power District 141415th Street Columbus, NE 68601

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING COOPER NUCLEAR STATION THIRD INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUESTS FOR RELIEF (TAC NO. MA2138)

Dear Mr. Horn:

By letter dated Ar,ril 23,1998, the Nebraska Public Power District submitted several requests for relief related to 'Ae third 10-year interval inservice Inspection Program for the Cooper Nuclear Station. Base'; on our ongoing review of these relief requests (RI-13, RI-17, and Rl-25), the staff has developed the enclosed request for additional information (RAl).

You are rr, quested to provide a response to the enclosed RAI within 30 days of the receipt of this lette, In addition, to expedite the review process, please send a copy of the your response to the NRC's contractor, INEEL, at the following address:

MichaelT. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 If there are any questions conceming the RAI, please contact me at (301) 415-1336.

Sincerely,

~

/

f  :

l- James R. , Senior Project Manager l Project Directorate IV-1 Division of Reactor Projects Ill/lV Office of Nuclear Reactor Regu;ation Docket No. 50-298 l

Enclosure:

Requestfor AdditionalInformation l cc w/ encl: See next page l

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Mr. G. R. Horn Nebraska Public Power District 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 1040 O Street Columbus, NE 68602-0499 Box 80869 Lincoln, NE 68501 Nebraska Public Power District ATTN: Mr. J. H. Swailes MidAmerican Energy Vice President of Nuclear Energy ATTN: Dr. William D. Leech, Manager-Nuclear P. O. Box 98 907 Walnut Street Brownville, NE 68321 P. O. Box 657 Des Moines, IA 50303-0657 Randolph Wood, Director Nebraska Department of Environmental Nebraska Public Power District l Control ATTN: Mr. B. L. Houston, Nuclear l P. O. Box 98922 Licensing & Safety Manager Lincnin, NE 68509-8922 P. O. Box 98 Brownville, NE 68321 i 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. Cher>1 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 Intergovemmental Cooperation

Department of Natural Resources t P.O. Box 176 Jefferson City, MO 65102 l

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REQUEST FOR ADDITIONAL INFORMATION RFI ATED TO REQUESTS FOR RFI IEF FROM CERTAIN ASME CODE REQUIREMENTS .)

FOR THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM COOPER NUCI FAR STATION

1. Scone / Status of Review Throughout the service life of a water-cooled nuclear power facility,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 the ASME Code,Section XI, " Rules for 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 requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection intervals 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 the interval, subject to the limitations and modifications listed therein. The components (including supports) may meet examination requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to -

the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval. The licensee, Nebraska Public Power District, prepared the Third 10-Year ISI Program to meet the requirements of the 1989 Edition of the ASME Code Section XI. The third 10-year interval began March 1,1996.

The staff has reviewed the available information in the licensee's April 23,1998, submittal. Based on this review, the staff has concluded that the information and/or clarification described in the next section is required to complete the review of the licensee's requests for relief.

2. Additional Information Renuired

a. Request for Relief RI-17, Revision 1. The licensee is proposing an attemative to the minimum examination requirements of ASME Code Case N-509 for several Class 1 piping integral attachment welds, in an SER dated October 23,1997, the licensee was authorized to use Code Case N-509 and committed to perform a minimum 10% examination of all Class 1,2, and 3 piping, pump, and valve integral attachment welds.

Code Case N-509 significantly reduces the number of examinations (from 100 to 10%) required during each interval; this is consistent with the sampling i l l \

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2 philosophy used by the Code for other Examination Categories. However, no i

guidance is given for which components are to be examined; therefore, the j licensee may use a certain level of discretion when choosing examination items.

Do additional integrally welded attachments, not currently being examined, exist within the same Class 1 systems as those for which relief is being requested?

Are there other welds that could be examined to provide the minimum required to meet Code Case N-5097 Please provide further information, including lists of: 1) l the total number of attachment welds in all Class 1 piping systems; 2) the number scheduled for examination during the interval; and 3) th1 estimated percentage of the total population obstructed by clamps, restraints, or other appurtenances,

b. Request for Relief Rl 25, Revision 0. The licensee is requesting relief, based on impracticality, for the VT-1 visual examinations required for integral attachment welds on Class 3 Service Water Pumps, in an SER dated October l 23,1997, the licensee was authorized to use Code Case N-509 and committed to perform a minimum 10% examination of all Class 1,2, and 3 piping, pump, and valve integral attachment welds. Additional guidance for selection of these welds is listed in Table 2500-1 of the Code Case.

The licensee stated:

i "There are four vertical service water pumps. Each SW pump has an interior and l exterior fillet weld attaching the pump discharge head to the pump column and a l fillet weld attaching the pump column to the mounting plate. The portions of l these welded attachments inside the discharge head are partially inaccessible i due to the limited access through the service port in the discharge head and the

, configuration of the pump column. A complete examination is not possible.

Approximately 60% of the total weld length is accessible for examination.

As an alternate examination, CNS will perform a visual examination (VT-1) of the

~ccessible portions of welded attachments on two SW pumps. This is a 50% '

sample of the welded attachments of the SW pump component supports."

l Code Case N-509 requires that attachments selected for examination be only l those on the outside surface of the pressure-rotalning component.

l Additionally, the Code Case requires that only 10% of the applicable welds be examined, within other restrictions. Based on these requirements, it is unclear whether this reliefis necessary. Please discuss these discrepancies and,if relief is still necessary, provide drawings of the Service Water Pumps, depicting location and access restrictions for the integrally welded attachments.

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