NLS2004068, Response to Request for Additional Information Regarding Relief Request RC-06
| ML041450302 | |
| 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 | |
| NLS2004068, TAC MC2059 | |
| Download: ML041450302 (5) | |
Text
Nebraska Public Power District Always there when you need us I OCFR50.55(a)
NLS2004068 May 18, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Request for Additional Infonnation Regarding Relief Request RC-06 Cooper Nuclear Station, Docket 50-298, DPIR-46
References:
I.
Letter to U.S. Nuclear Regulatory Commission from Randall K. Edington (Nebraska Public Power District) dated February 12, 2004, "Inser'ice Inspection Relief Requests PR-03, RC-06, RC-07, RI-17, RI-31, RI-32 and Rl-33 (Nl S2004009)
- 2.
Ietter to Randall K. Edinglon (NPPD) from U. S. Nuclear Regulatory Commission dated April 23, 2004, "Cooper Nuclear Station - Request for Additional Information Regarding Relief Request RC-06 (TAC NO.
MC2059)--
The purpose of this letter is for the Nebraska Public Power District (NPPD) to submit a response to a Request for Additional Infonnation (RAI) regarding Inservice Inspection (ISI) Relief Request RC-06 (Reference 2).
In Reference I above, NPPD requested that 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 the NRC staff on April 5, 2004, NRC concerns with Relief Request RC-06 and the potential to request relief in accordance with ASME Code Case N-649 were discussed. It was conclude(d that the NRC would providel these questions in a RAI.
The Attachment to this letter provides NPPD's response to the RAI.
If you should have any questions concerning this matter, please contact Paul V. Fleming at (402) 825-2774.
COOPERNUCLEARSTATION A
wl P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2004068 Page 2 of 2 Si I
- 7re1y>/
e1e R dall K. Edington Vice President - Nuclear and Chief Nuclear Officer
/rar Attachment cc:
Regional Administrator Iv/
attachment USNRC - Region IV Senior Project Manager Nv/ attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector Nv/ attachment USNRC NPG Distribution wv/o attachment Records Nv/ attachment
NLS2004068 Attachment I Page I of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUEST RC-06 Cooper Nuclear Station, Docket 50-298, DPR46
- 1.
NRC ReqUtest The licensee requests relieffrom Subsubarticle 1WE-5240 or th/e 1992 Edition and the 1992 Addenda of Section XI oftie American Societyl of Mechanical Engineers Code.
IIVE-5240 (by reference to the requirements of Subsubarticle IXVA-5240) requires the licensee to peiforim a 1T-2 visual examination during a pressure test to detect evidence of leakage. The licensee requests relieffrom performing a J'T-2 visual examination during pressure testing th/e containnientpressure retaining components. Alternativelyj t/ie licensee will perform VT-I or VT-3 visual examination, as appropriate. To get a clear understanding of how the licensee will determine the appropriateness of 1T-1 and VT-3 visual examination, the licensee is requested to provide t/iefollow'ing information:
(a)
The intent of IWJ'E-5240 is to detect the areas of leakage during pressure testing of the contaiimtenitpressu-re boutndai' components. Iloit' tozild you peiformi ti/e examination of a leaking component which is in part inaccessible and detect leakage area (s) (e.g., Type B testing of vent pipes between the dariell and the suppression chamber)?
NPPD Response Article IWE-5000 is only applicable to repairs and replacement and within the limitation stated in IWE-5000.
If an area that is normally inaccessible requires a repair or replacement, the area would be made accessible to perform the repair or replacement (e.g., removal of the guard pipe or the concrete). The required examination, whether it is a VT-2, VT-3 or VT-I, would be performed prior to the full restoration of the configuration (i.e., reinstallation of the guard pipe or concrete).
NRC Request (b)
In some cases, JWE-5222 permits deferral ofpressure test follows ing minor repair Hlow, wouldyou perform the examination of tie repaired areas to ensure that th/e repaired areas *iill not be leaking during the deferralperiod?
NPPD Response NPPD is not requesting relief from the provisions of ]WE-5222. IWE-5222 allows deferral of the leakage test for minor repairs or modifications to the pressure retaining
NLS2004068 Attachment I Page 2 of 2 boundary, provided nondestructive testing is performed in accordance with the approved repair program. The nondestructive testing in accordance with an approved repair program Nvill provide reasonable assurance that the repaired area is not leaking until the next scheduled leak test is performed.
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©D I
Correspondence Number: NLS2004068 The following table identifies those actions committed to by Nebraska Public Power 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 M\\Ianager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE None
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