NLS2020053, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI, Relief Request RR5-04

Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI, Relief Request RR5-04

ML20248H484
Person / Time
Site:	Cooper
Issue date:	08/26/2020
From:	Dent J Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2020053
Download: ML20248H484 (4)

Text

H Nebraska Public Power District "Always there when you need us" 10 CFR 50.55a NLS2020053 August 26, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI, Relief Request RRS-04 Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46

Dear Sir or Maclain:

In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv), and Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," dated July 28, 2004, Nebraska Public Power District (NPPD) requests NRC approval to use a specific provision of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, for Cooper Nuclear Station (CNS). Specifically, NPPD requests approval to use IWA-4540(b) of the 2017 Edition of the ASME B&PV Code.

NPPD requests approval of this request by September 23, 2020, to support the upcoming CNS refueling outage scheduled in September 2020.

No formal licensee commitments are being made in this letter.

Should you have any questions concerning this matter, please contact Linda Dewhirst, Regulatory Affairs & Compliance Manager at (402) 825-5416.

Dent, Jr.

Vice President and Chief Nuclear Officer

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Attachment:

Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv), Relief Request RRS-04

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COOPER NUCLEAR STATION 72676 648A Ave/ P.O. Box 98 / Brownville, NE 68321 http://www.nppd.com

NLS2020053 Page2 of2 cc: Regional Administrator w/ Attachment USNRC - Region IV Senior Project Manager w/ Attachment USNRC - NRR Plant Licensing Branch IV Senior Resident Inspector w/ Attachment USNRC-CNS NPG Distribution w/o Attachment CNS Records w/ Attachment

NLS2020053 Attachment Page 1 of2 Attachment Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv)

Relief Request RRS-04 Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv) and the guidance provided in Reference 1, Nebraska Public Power District (NPPD) requests Nuclear Regulatory Commission (NRC) approval to use specific provisions of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, for Cooper Nuclear Station (CNS). Specifically, NPPD requests approval to use IWA-4540(b) of the 2017 Edition of the ASME B&PV Code.

ASME Code Component(s) Affected:

All Class 1, 2, and 3 items located in the ASME Section XI boundaries.

Requested Date for Approval:

Approval is requested by September 23, 2020, to support the CNS refueling outage scheduled for September 2020.

Applicable Code Edition and Addenda

INTERVAL ISi INTERVAL PLANT EDITION SCHEDULED INTERVAL START END 2007 Edition, Cooper Nuclear 5 through 2008 04/01/2016 2/28/2026 Station Addenda Proposed Subsequent Code Edition and Addenda (or Portion):

CNS performs repair/replacement activities in accordance with a site program based on an edition of ASME Section XI which, at present, is the 2007 Edition through the 2008 Addenda.

Pursuant to 10 CFR 50.55a(g)(4)(iv), NPPD requests permission to utilize IWA-4540(b) from the 2017 Edition. This subparagraph outlines items that are exempt from pressure testing after repair/replacement activities.

Related Requirements:

10 CFR 50.55a(g)(4)(iv) states:

NLS2020053 Attachment Page 2 of2 "Inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (a) of this section, subject to the conditions listed in paragraph (b) of this section, and subject to Commission approval. Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met. "

10 CFR 50.55a(b)(2) incorporates by reference Section XI, Division 1, of the ASME B&PV Code 2017 Edition as approved in Reference 3. NPPD is requesting to use IWA-4540(b) of the 2017 Edition of ASME Section XI to utilize the exemptions listed. There are no related requirements or applicable conditions associated with this subparagraph, IWA-4540(b).

Duration of Proposed Request:

The duration of this request will continue for the remainder of the site's current Inservice Inspection interval.

References:

1. NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," dated July 28, 2004

2. U.S. Nuclear Regulatory Commission Memorandum from D. Rudland (Senior Level Advisor, Division of New and Renewed Licenses) to Anna H. Bradford (Director, Division of New and Renewed Licenses), "Summary of the June 25, 2020, Public Meeting with the Nuclear Industry to Discuss Title 10 of the Code of Federal Regulations Section 50.55a(b)(2)(xxvi) Condition on the Pressure Testing of Class 1, 2, and 3 Mechanical Joints," dated July 8, 2020 (ML20189A286)

3. Federal Register, 85 FR 26540, dated May 4, 2020, "American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference - Final rule" Precedent:

Southern Nuclear letter to the U.S. Nuclear Regulatory Commission, "Vogtle Electric Generating Plant Units 1&2, VEGP-ISI-ALT-04-06, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI," dated July 31, 2020 (ML20213C712).