NLS2004063, Resubmittal of Inservice Inspection Relief Request PR-03
| ML041460314 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/18/2004 |
| From: | Edington R Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2004063 | |
| Download: ML041460314 (5) | |
Text
Nebraska Public Power District Always there when you need us I OCFR50.55(a)
NLS2004063 May IS, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Resubmittal of Inservice Inspection Relief Request PR-03 Cooper Nuclear Station, Docket 50-298, DPR-46
Reference:
Letter to U.S. Nuclear Regulatory Commission from Randall K. Edington (Nebraska Public Power District) dated February 12, 2004, "Inservice Inspection Relief Requests PR-03, RC-06, RC-07, RI-17, RI-31, RI-32 and RI-33" (NLS2004009)
The purpose of this letter is for the Nebraska Public Power District (NPPD) to resubmit Inservice Inspection (IS[) Relief Request PR-03, Revision 2.
In the letter referenced above, NPPD requested the Nuclear Regulatory Commission (NRC) grant relief from certain ISI code requirements for Cooper Nuclear Station (CNS) pursuant to IOCFR50.55(a). During a teleconference between NPPD and tile NRC staff on March 25,2004, NRC concerns with Relief Request PR-03, Revision 2, as wfitten, wvere discussed.
The Attachment to this letter contains NPPD's changes to ISI Relief Request PR-03, Revision 2, to address the NRC staff concerns.
If you should have any questions concerning this matter, please contact Paul V. Fleming at (402) 825-2774.
R ndall K. Edington Vice President - Nuclear and Chief Nuclear Officer
/rar Attachnmient COOPERNUCOEARSTATION ol P.O. Box 98/ Brownville, NE 6832140098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2004063 Page 2 of 2 cc:
Regional Administrator w/ attachment USNRC - Region IV Senior Project Manager w/ attachment USNRC - NRR Project Directorate IV-I Senior Resident Inspector w/ attachment USNRC NPG Distribution w/o attachment Records w/ attachment
NLS2004063 Attachment I Page l of2 RELIEF REQUEST NUMBER: PR-03, REVISION 2 COMPONENT IDENTIFICATION Code Classes:
1, 2, and 3
References:
IWA-5250 Examination Categories:
B-P, C-H, and D-A Item Numbers:
B 15.10 through B 15.71, C7.10 through C7.80, and D 1.10
==
Description:==
Alternate corrective measures for bolted connections.
Component Numbers:
All Class 1, 2, and Class 3 pressure retaining components subject to system pressure testing.
APPLICABLE CODE EDITION AND ADDENDA 1989 Edition, No Addenda CODE REOUIREMENT IWA-5250(a)(2) requires, if leakage occurs at a bolted connection, that the bolting be removed, examined by VT-3 visual examination for corrosion, and evaluated in accordance with IWA-3100.
BASIS FOR RELIEF In the event of a bolted connection leak detected during the conduct of a system pressure test, the 1989 Edition, ASME Section XI requirements specify that all bolting must be removed for the purpose of a VT-3 visual examination and evaluation. This requires removing the component or piping system from service, which could result in a plant shutdown, a delay of plant startup or, for continued operation, a reduction in plant safety.
Nebraska Public Power District's (NPPD) proposed alternative to requirements of the 1989 Edition of the Code was approved by the Nuclear Regulatory Commission (NRC). Specifically, NPPD would evaluate the bolting to determine its susceptibility to corrosion, perform a more in-depth evaluation as applicable and if necessary, remove the bolt closest to the source of leakage and evaluate the bolt in accordance with IWA-3100(a).
Since the granting of the above relief, the Section XI Code requirements have changed making clear the purpose of the examination is to detect degradation of bolting due to leakage from borated systems. The ASME Code Section Xl, 1998 Edition, 1999 Addenda, revised Subsubarticle IWA-5250 (a)(2) as follows:
"If leakage occurs at a bolted connection in a system bora ted for the puipose of controlling r eactiviij, one of the bolts shall be r emoved, 1T-3 examnined, and evaluiated in accordance with IT1'A-3100. Tle bolt selected shall be one closest to the source of leakage. When the removed
NLS2004063 Attachment I Page 2 of 2 RELIEF REQUEIST NUMBER: PR-03, REVISION 2 (Continued) bolt has evidence of degradation, all remaining bolts in t/ie connection shall be r enmoved, 'T-3 examined, and evaluated in accordance withi 1J'A-3100. "
Under the revised subsubarticle, the examination is applicable to code piping of borated water systems. Cooper Nuclear Station (CNS) is a boiling water reactor and does not use borated water to control reactivity during normal plant operation.
No other changes made in the 1999 Addenda are related to the change made in Subsubarticle IWA-5250. System pressure testing requirements contained in Examination Tables IWB-2500-1, IWC-2500-1 and IWD-2500-l1 wvere not affected. Repair and replacement activities must still be performed in accordance wvith the repair and replacement program, as applicable.
NPPD requests approval to use the corrective action requirements of ASME Section XI, 1998 Edition, 1999 Addenda, Subsubarticle IWA-5250 in accordance with I OCFR50.55a(g)(4)(iv).
PROPOSED ALTERNATE PROVISIONS In lieu of the requirements contained in Subsubarticle IWA-5250 of the 1989 Edition of Section Xl, NPPD will comply with the corrective action requirements for bolted connections contained in Subsubarticle IWA-5250 of the 1998 Edition, 1999 Addenda of Section XI.
APPLICABLE TIME PERIOD Approval is requested for the third ten-year interval of the ISI Program for CNS, which ends on February 28,2006.
PR-03, Revision I was approved by the NRC on October 23, 1997 (TAC No. M94000).
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ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS(
Correspondence Number: NLS2004063 The following table identifies those actions committed to by Nebraska Public Powver District. (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing & Regulatory Affairs Manager at Cooper Nuclear Station of any questions regarding this document. or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE None PROCEDURE 0.42 REVISION 15 l
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