ML22010A263

NRR E-mail Capture - Cooper - Final RAI Relief Request RR5-01 Revision 1

ML22010A263
Person / Time
Site:	Cooper
Issue date:	01/10/2022
From:	Thomas Wengert NRC/NRR/DORL/LPL4
To:	Dewhirst L Nebraska Public Power District (NPPD)
Wengert T
References
L-2021-LLR-0046
Download: ML22010A263 (5)

Text

From: Wengert, Thomas Sent: Monday, January 10, 2022 3:45 PM To: Dewhirst, Linda R.

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

Subject:

Cooper - Final RAI RE: Relief Request RR5-01 Revision 1 (EPID L-2021-LLR-0046)

Attachments: Final RAI for Cooper Proposed Weld Overlay Alternative.pdf On January 4, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff sent Nebraska Public Power District (NPPD) the draft Request for Additional Information (RAI) identified below.

This RAI relates to Relief Request RR5-01, Revision 1, dated June 21, 2021, concerning a potential proposed alternative dissimilar metal weld overlay repair for Cooper Nuclear Station.

On January 10, the NRC and NPPD staffs held a conference call to clarify the draft RAI. At the conclusion of the call, NPPD 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 Agencywide Documents Access and Management System (ADAMS). As agreed, please provide a response to this RAI within 30 days of this correspondence.

From: Wengert, Thomas Sent: Tuesday, January 04, 2022 3:38 PM 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: Relief Request RR5-01 Revision 1 (EPID L-2021-LLR-0046)

By letter dated June 21, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21172A301), Nebraska Public Power District (the licensee) proposed an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI at Cooper Nuclear Station (Cooper). Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, paragraph (z)(1), the licensee submitted Relief Request RR5-01, Revision 1, proposing an alternative dissimilar metal weld overlay repair on the basis that the proposed alternative provides an acceptable level of quality and safety.

The U.S. Nuclear Regulatory Commission (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 draft RAI.

Tom Wengert Project Manager - Cooper Nuclear Station NRR/DORL/LPL4 (301) 415-4037

Hearing Identifier: NRR_DRMA Email Number: 1481 Mail Envelope Properties (MN2PR09MB5449C61527352D6F52BA310C8F509)

Subject:

Cooper - Final RAI RE: Relief Request RR5-01 Revision 1 (EPID L-2021-LLR-0046)

Sent Date: 1/10/2022 3:44:44 PM Received Date: 1/10/2022 3:44:00 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 2616 1/10/2022 3:44:00 PM Final RAI for Cooper Proposed Weld Overlay Alternative.pdf 139718 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST NO. RR5-01, REVISION 1 ALTERNATIVE FOR DISSIMILAR METAL WELD OVERLAY REPAIR NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 By letter dated June 21, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21172A301), Nebraska Public Power District (the licensee) proposed an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI at Cooper Nuclear Station (Cooper). Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, paragraph (z)(1), the licensee submitted Relief Request RR5-01, Revision 1, proposing an alternative dissimilar metal weld overlay repair on the basis that the proposed alternative provides an acceptable level of quality and safety.

To complete its review, the U.S. Nuclear Regulatory Commission (NRC) staff requests the following additional information.

Regulatory Basis The inservice inspection (ISI) of ASME Code Class 1, 2, and 3 components is to be performed in accordance with Section XI of the ASME Code and applicable edition and addenda as required by 10 CFR 50.55a(g), Preservice and inservice inspection requirements, except where specific relief has been granted by the NRC pursuant to 10 CFR 50.55a(g)(6)(i),

Impractical ISI requirements: Granting of relief.

Pursuant to 10 CFR 50.55a(z), Alternatives to codes and standards requirements, alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC if: (1) the proposed alternatives would provide an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The licensee submitted the request pursuant to 10 CFR 50.55a(z)(1), on the basis that the proposed alternative would provide an acceptable level of quality and safety.

Request for Additional Information (RAI)

RAI-NPHP-01 The licensees application states that the full structural weld overlay will be designed consistent with the requirements for the design thickness, length, and location of the overlay in accordance with Nonmandatory Appendix Q, Weld Overlay Repair of Class 1, 2, and 3 Austenitic Stainless Steel Piping Weldments, and IWB-3640 of ASME Code,Section XI, 2007 Edition through the 2008 Addenda, as referenced by Nonmandatory Appendix Q. In the event that an overlay 1

repair is required, identify when the design analysis will be completed and available for NRC staff inspection/audit.

RAI-NPHP-02 The licensees application does not provide any discussion regarding the growth of a flaw found in the dissimilar metal weld. Explain how the potential for flaw growth in the original dissimilar metal weld will be evaluated to demonstrate the adequacy of the weld overlay design.

RAI-NPHP-03 Confirm whether the licensee intends to submit acceptance examination and preservice inspection results to the NRC, or make them available for NRC staff inspection, after installation of the weld overlay and before the restart of the plant. This is to confirm that the weld overlay installation has satisfied the proposed alternative.

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