ML21258A263

NRR E-mail Capture - Cooper - Final RAI Alternative Request RS-01

ML21258A263
Person / Time
Site:	Cooper
Issue date:	09/15/2021
From:	Thomas Wengert NRC/NRR/DORL/LPL4
To:	Dewhirst L Nebraska Public Power District (NPPD)
Wengert T
References
L-2021-LLR-0044
Download: ML21258A263 (6)

Text

From: Wengert, Thomas Sent: Wednesday, September 15, 2021 12:55 PM To: Dewhirst, Linda R.

Cc: Van Der Kamp, David W.; Forland, Thomas J.; Dixon-Herrity, Jennifer

Subject:

Cooper - Final RAI RE: Alternative Request RS-01 (EPID L-2021-LLR-0044)

Attachments: Cooper - Final RAI Regarding Alternative Request RS-01.pdf On September 15, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff sent Nebraska Public Power District (the licensee) the draft Request for Additional Information (RAI) identified below. This RAI relates to Alternative Request RS-01, Revision 0, dated June 16, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21167A098), for an alternative to certain snubber testing and inspection requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Cooper Nuclear Station (Cooper).

The licensee subsequently informed the NRC staff that the information requested was understood and that no additional clarification of the RAI was necessary. A publicly available version of this final RAI (attached with Draft removed) will be placed in the NRCs ADAMS system. As agreed, please provide a response to this RAI within 30 days of this correspondence.

From: Wengert, Thomas Sent: Wednesday, September 15, 2021 8:54 AM To: Dewhirst, Linda R. <lrdewhi@nppd.com>

Cc: Van Der Kamp, David W. <dwvande@nppd.com>; Forland, Thomas J. <tjforla@nppd.com>; Dixon-Herrity, Jennifer <Jennifer.Dixon-Herrity@nrc.gov>

Subject:

Cooper - Draft RAI RE: Alternative Request RS-01 (EPID L-2021-LLR-0044)

By letter dated June 16, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21167A098), Nebraska Public Power District (the licensee) submitted Alternative Request No. RS-01, Revision 0 to the U.S. Nuclear Regulatory Commission (NRC) for an alternative to certain snubber testing and inspection requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Cooper Nuclear Station (Cooper).

The NRC staff reviewed the submittal and determined that additional information, as described in the attached request for additional information (RAI), is required for the staff to complete its review of this application. This RAI is identified as draft at this time to confirm your understanding of the information that the NRC staff needs to complete the evaluation. If the request for information is understood, please respond to this RAI within 30 days of the date of this request.

Please contact me if you would like to set up a conference call with the NRC staff to clarify this request for information.

Tom Wengert Project Manager - Cooper Nuclear Station NRR/DORL/LPL4

(301) 415-4037 Hearing Identifier: NRR_DRMA Email Number: 1349 Mail Envelope Properties (MN2PR09MB54499F5C1A6C6774B02A86B08FDB9)

Subject:

Cooper - Final RAI RE: Alternative Request RS-01 (EPID L-2021-LLR-0044)

Sent Date: 9/15/2021 12:55:26 PM Received Date: 9/15/2021 12:55:00 PM From: Wengert, Thomas Created By: Thomas.Wengert@nrc.gov Recipients:

"Van Der Kamp, David W." <dwvande@nppd.com>

Tracking Status: None "Forland, Thomas J." <tjforla@nppd.com>

Tracking Status: None "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>

Tracking Status: None "Dewhirst, Linda R." <lrdewhi@nppd.com>

Tracking Status: None Post Office: MN2PR09MB5449.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 2516 9/15/2021 12:55:00 PM Cooper - Final RAI Regarding Alternative Request RS-01.pdf 151513 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION REGARDING ALTERNATIVE REQUEST RS-01, REVISION 0 SNUBBER VISUAL EXAMINATION EXTENSION NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 By letter dated June 16, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21167A098), Nebraska Public Power District (NPPD, the licensee) submitted Alternative Request No. RS-01, Revision 0 to the U.S. Nuclear Regulatory Commission (NRC) for an alternative to certain snubber testing and inspection requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Cooper Nuclear Station (Cooper). Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, Codes and Standards, paragraph (z)(1), the licensee stated that the proposed alternative provides an acceptable level of quality and safety. The NRC staff reviewed the submittal and determined that additional information is needed to complete the review, as indicated in the request for additional information (RAI) below.

Regulatory Requirements The NRC regulations in 10 CFR 50.55a(g)(4), Inservice inspection standards requirement for operating plants, state, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3 must meet the inservice inspection (ISI) requirements set forth in Section XI of the editions and addenda of the ASME Boiler and Pressure Vessel Code (BPV Code) or ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for snubber examination and testing that become effective subsequent to editions and addenda specified in 10 CFR 50.55a(g)(2) and (3) and that are incorporated by reference in 10 CFR 50.55a(a), to the extent practical within the limitations of design, geometry, and materials of construction of the components.

The NRC regulations in 10 CFR 50.55a(b)(3)(v)(B), Snubbers: Second provision, state that licensees must comply with the provisions for examining and testing snubbers in ASME OM Code, Subsection ISTD, Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants, of the ASME OM Code, and make appropriate changes to the technical specifications or licensee-controlled documents when using the 2006 Addenda and later editions and addenda of Section XI of the ASME BPV Code.

The applicable Code of Record for the Inservice Testing (IST) Program at Cooper is ASME OM Code, 2004 Edition through 2006 Addenda. ASME OM Code, Subsection ISTD, specifies the IST Program requirements for inservice examination and testing of snubbers.

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ASME OM Code Case OMN-13, Revision 0, Requirements for Extending Snubber Inservice Visual Examination Interval at LWR [Light Water Reactor] Power Plants, allows the extension of the visual examination interval for snubbers up to 10 years, if all of the provisions specified in OMN-13 are met. The NRC accepted the use of ASME OM Code Case OMN-13, Revision 0, in NRC Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, as incorporated by reference in 10 CFR 50.55a.

Request for Additional Information

RAI-1

The implementation of Code Case OMN-13 requires that all provisions of Code Case OMN-13, Section 2, General Requirements, be met before extension of the visual examination interval to once every 10 years. Cooper Alternative Request RS-01 and the Cooper fifth 10-year IST Program (ADAMS Accession No. ML16078A128) do not provide details about meeting these requirements. Explain how these general requirements to implement Code Case OMN-13 will be met.

RAI-2

Coopers fifth 10-year interval began on March 1, 2016, and is scheduled to end on February 28, 2026. Coopers fifth 10-year snubber program, Section 2.3 Inservice Examination, states, in part, that Cooper is utilizing approved Code Case OMN-13. However, the program does not specify the date when Code Case OMN-13 was initially implemented to extend the visual examination interval from 48 months to up to 10 years. In addition, Cooper Alternative Request RS-01 does not specify when Code Case OMN-13 was initially implemented to extend the visual examination interval to up to 10 years. Provide the date when Code Case OMN-13 was initially implemented at Cooper.

RAI-3

Cooper Alternative Request RS-01, Section 4, Reason for Request, states, in part, that because of the strict 10-year interval requirement, Cooper would be implementing a less efficient overall program for the mechanical snubbers, and would be required to perform many mechanical/hydraulic snubber examinations on a four refueling cycle interval rather than every five refueling cycles. Explain how implementation of the Code Case OMN-13 requirements to complete the visual examination of all snubbers within 10 years is less efficient.

RAI-4

Code Case OMN-13, Section 3.4, Review of Operational Readiness Test Data, states that All inservice test data acquired since implementation of the requirements of this Code Case shall be evaluated for indications of snubber degradation or other anomalies. This includes a review of test traces, where available. The results of its evaluation shall be used (a) to identify snubbers that are subject to progressive degradation, [and] (b) to identify severe operating environments not previously identified. Summarize the snubber test data and evaluations since initial implementation of Code Case OMN-13, as required by Section 3.4, to confirm the operational readiness of the snubbers beyond the 10-year interval.

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RAI-5

Code Case OMN-13, Section 2, General Requirements, paragraph (a), states that the requirements in OMN-13 are in addition to the service life monitoring (SLM) requirements in ASME OM Code, Subsection ISTD, paragraph ISTD-6000. ISTD-6000 requires that the service life of all snubbers be evaluated every refueling outage. Provide the service life and expiration dates of the 155 mechanical and 53 hydraulic snubbers evaluated during the previous refueling outage (RE31).

RAI-6

Cooper Alternative Request RS-01, Section 5, Proposed Alternative and Basis for Use, fourth paragraph, states, in part, that CNS [Cooper] performs a service life snubber activity after approximately 10 years in service for all mechanical snubbers. ISTD-6000 requires that the snubber service life be evaluated every refueling outage. Explain the discrepancy between the required service life evaluation every refueling outage (per ISTD-6000) versus the Cooper evaluation of service life approximately every 10 years.

RAI-7

Cooper Alternative Request RS-01, Section 1, ASME Code Component(s) Affected, proposes that the request apply to all snubbers covered by ASME OM Code, paragraph ISTA-1100, Scope. However, Section 5 of the request discusses only mechanical snubbers. Provide the applicable information to support the alternative request for the Cooper hydraulic snubbers.

RAI-8

Cooper Alternative Request RS-01 proposes to extend the visual examination interval for all 155 mechanical and 53 hydraulic snubbers beyond the 10-year interval. To enable the NRC staff to evaluate the operational readiness of the snubbers beyond 10 years, please summarize the historical data for the snubber examinations and testing performed after the initial implementation of Code Case OMN-13 at Cooper.

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