ML25015A026
| ML25015A026 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/19/2024 |
| From: | Sisco C Nuclear Utility Group on Environmental Qualification (NUGEQ), Winston & Strawn, LLP |
| To: | Geoffrey Miller NRC/RGN-IV/DORS |
| References | |
| IR 2024003 | |
| Download: ML25015A026 (1) | |
Text
From:
Sisco, Carlos To:
Geoffrey Miller Cc:
Michael Hay; Nicholas Taylor; Douglas Dodson; Gregory Kolcum; Kent Chambliss; Geoffrey Birkemeier; Matthew McConnell; Hopkins, Matt; rewise@contech-inc.net
Subject:
[External_Sender] NUGEQs Concern with Generic Implications & Request for Clarification re Assessment of Performance Deficiency at Cooper as a § 50.49 NCV Date:
Thursday, December 19, 2024 1:21:28 PM Attachments:
12-19-24 NUGEQ Ltr to NRC re Generic Implications of Cooper 50.49(f) NCV.pdf The Nuclear Utility Group on Equipment Qualification (NUGEQ or Group) hereby submits this letter as a result of the Groups review of the Green Finding and NCV levied against Cooper Nuclear Station on November 5, 2024. Inspection Report 05000298/2024003 identified a performance deficiency associated with a violation of 10 C.F.R. 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, for the licensees failure to properly maintain environmental qualification of process line joints within the environmental qualification boundaries. Specifically, our concern centers on how the NCV expands the applicability of 10 C.F.R. 50.49 to include process line fittings to mechanical components that are beyond the connection interface with the EQ equipment.
It is NUGEQs position that NCV 2024003-01 represents a new staff position that expands the equipment scope of the EQ final rule as defined by § 50.49(b). Without further clarification, the ramifications of this violation have the potential to significantly increase the scope of equipment subject to 10 CFR 50.49 by requiring the inclusion of mechanical equipment with NPT connections, including but not limited to: (1) Hydraulic Operated Valves; (2) Pneumatic lines associated with Air Operated Valves; (3) Manual vent and drain valves; (4) 3-valve or 5-valve manifolds; and (4) excess flow check valves.
Request for Clarification Given the generic implications of NCV 2024003-01 citing the performance deficiency against § 50.49(f), the Group requests Staff clarification that § 50.49 does not apply to purely mechanical components (e.g., 3-valve manifolds, vent/drain valves, etc.) or their fittings, including any thread sealant, that are external to the connection interfaces of the electric or electro-mechanical equipment subject to § 50.49.
Carlos Sisco Senior Paralegal Winston & Strawn LLP T: +1 202-282-5000 D: +1 202-282-5907 winston.com ADAMS Accession # ML25015A026
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