NLS2006051, Revision of Relief Request PR-02
| ML061710101 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/15/2006 |
| From: | Edington R Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2006051, PR-02 | |
| Download: ML061710101 (7) | |
Text
N Nebraska Public Power District Always there when you need us NLS2006051 June 15, 2006 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Revision of Relief Request PR-02 Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
Letter to U. S. Nuclear Regulatory Commission from Randall K. Edington (Nebraska Public Power District) dated February 23, 2006, "10 CFR 50.55a Requests for Fourth Ten-Year Inservice Inspection Interval" (NLS2006015).
The purpose of this letter is for the Nebraska Public Power District (NPPD) to provide a revised Relief Request PR-02 submitted by the Reference letter. The Attachment to this letter is Relief Request PR-02 with the clarifications requested by the Nuclear Regulatory Commission (NRC) in a telephone conference on May 22, 2006 between Brian Benney, NRC Project Manager, et. al. and David Van Der Kamp, NPPD Acting Licensing Manager, et. al.
These clarifications have no impact on the reason for the request or the basis for use of the proposed alternative.
Should you have any questions concerning this matter, please contact Paul Fleming, Licensing Manager, at (402) 825-2774.
Randall K. Edington Vice President - Nuclear and Chief Nuclear Officer
/em Enclosure COOPER NUCI.EAR STATION /VcI)-I7 P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2006051 Page 2 of 2 cc: Regional Administrator w/attachment USNRC - Region IV Cooper Project Manager w/attachment USNRC - NRR Project Directorate IV-I Senior Resident Inspector w/attachment USNRC - CNS Nebraska Health and Human Services w/attachment Department of Regulation and Licensure NPG Distribution w/o attachment CNS Records w/attachment
NLS2006051 Attachment Page I of 4 10 CFR 50.55a Request Number PR-02 Definition of Pressure Retaining Boundary for System Leakage Test Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)
Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety ASME Code Component(s) Affected Code Class: I Examination Category: B-P Item Number: B 15.10 Component Numbers: All Components Subject to Pressurization During a System Leakage Test
Applicable Code Edition and Addenda
ASME Code Section X1, 2001 Edition, 2003 Addenda
Applicable Code Requirement
Paragraph IWB-5222(a)
Article IWB-5000, "System Pressure Tests," Sub-subarticle IWB-5220, "System Leakage Test," Paragraph IWB-5222, "Boundaries," states that:
(a) The pressureretainingboundar,' dutring the system leakage test shall correspond to the reactorcoolant boundawy with all valves in theposition requiredfor nornmal reactoroperationstartulp. The visual examination shall, however, extend to and inchlde the second closed valve at the boundai, extremit.
(b) The pressureretainingboundary during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class I pressure retainingcomponents within the system bolindary.
Table IWB-2500-1, Category B-P, Note 2, requires that the system leakage test be conducted prior to plant startup following a refueling outage.
Reason for Request
Pursuant to 10 CFR 50.55a, "Codes and Standards," Paragraph (a)(3), relief is requested from the requirements of ASME Code Section XI requirements for performing a system leakage test using the boundaries stated in Paragraph IWB-5222(a) because performing the pressure test with this boundary would result in a hardship without a compensating increase in quality and safety due to excessive radiation exposure and personnel safety concerns (temperature levels in the drywell).
NLS2006051 Attachment Page 2 of 4 10 CFR 50.55a Request Number PR-02 (Continued)
Definition of Pressure Retaining Boundary for System Leakage Test Proposed Alternative and Basis for Use In lieu of a system leakage test ddring reactor startup, as required by IWB-5222(a), a system pressure test is performed at the pressure associated with 100% rated reactor power.
a) The outboard Feedwater check valves and the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) injection check valves are the Class .1boundary valves and are closed for this test. The Feedwater check valves are normally open for reactor startup. The inboard check valve (FW-CV-I 6CV) on one feedwater line is kept open by Reactor Water Cleanup (RWCU) flow. The RWCU system is kept in service during the pressure tests. Thus the outboard Feedwater check valve and the RCIC injection check valve on this line will be pressurized during this test. The portion of piping between the other two Feedwater check valves including the HPCI injection line will not be pressurized.
b) The four outboard Main Steam Isolation Valves (MSIV) will be closed for the system pressure test and the ten-year system pressure test [IWB-5222(b)]. The inboard MSIVs are opened to pressurize the system to the outboard valves. Both Main Steam Drain Valves are open for pressure control. The outboard valves are the Class I boundary valves.
c) Both HPCI and both RCIC steam supply valves will be closed for the system pressure test following a refueling outage. These valves close automatically on low steam supply pressure. During the ten-year system pressure test [IWB-5222(b)], the system will be pressurized to the outboard valves. The outboard valves are the Class I boundary valves.
The position of the valves for the system leakage test as described above is consistent with the intent of IWB-5222(a). Abnormal lineups and installation ofjumpers is not required for the system leakage test. The valves described above are normally open during a reactor startup. In order to pressurize the reactor coolant pressure boundary for testing, these valves must be closed. Except as described above, the Class I boundary is pressurized as required by the code. The VT-2 inspection includes the entire reactor coolant pressure boundary.
Since the portions of the piping between the valves described above are operated at or above reactor pressure during normal operation, any through-wall leakage would be detected by the drywell leakage collection system, or by operations personnel on normal rounds.
NLS2006051 Attachment Page 3 of 4 10 CFR 50.55a Request Number PR-02 (Continued)
Definition of Pressure Retaining Boundary for System Leakage Test Performing a system pressure test at 100 percent reactor power would result in a hardship without a compensating increase in quality and safety. At 100% power primary containment is inerted and radiation levels are high. The proposed alternative provides reasonable assurance of operational readiness of the subject components.
In summary, three of the Feedwater Check valves, HPIC injection check valve, the outboard MSIVs, and the HPCI and RCIC steam supply valves will be closed during the system leakage test, but will be included in the VT-2 visual examination. A VT-2 examination will be performed during the system leakage test at a pressure not less than that associated with 100% rated reactor power and will provide reasonable assurance of the continued operational readiness of mechanical connections, extending to the Class 1 boundary. In addition, once at or near the end of the inspection interval the system leakage test shall extend to the Class I boundary as required by IWB-5222(b).
Based on the above, NPPD requests relief from the ASME Section XI requirements for performing a system leakage test using the boundaries stated in IWB-5222(a).
Duration of Proposed Alternative This proposed alternative will be used for the entire fourth ten-year interval of the ISI Program for CNS.
Precedents PR-02, Revision 2, was previously approved by the NRC for the third ten-year interval for CNS on October 23, 1997 (TAC No. M94000).
References
- 1. NPPD Letter NLS950157 to USNRC, "Third Ten-Year Interval Inservice Inspection Program," dated October 18, 1995.
- 2. USNRC letter to NPPD, "Cooper Nuclear Station - Request for Additional Infornation Regarding Third Ten-Year Interval Inservice Inspection Program," dated February 8, 1996 (TAC No. M94000).
- 3. NPPD Letter NLS960050 to USNRC, "Response to Request for Additional Information and Submittal of Revision I to the Third Ten-Year Interval Inservice Inspection Program," dated April 1H, 1996.
- 4. USNRC letter to NPPD, "Cooper Nuclear Station - Request for Additional Information Regarding Third Ten-Year Interval Inservice Inspection Program (TAC No. M94000)," dated June 3, 1996.
NLS2006051 Attachment Page 4 of 4
- 5. NPPD Letter NLS960131 to USNRC, "Response to Request for Additional Information Regarding Revision I to the Third Ten-Year Interval Inservice Inspection Program (TAC No. M94000) and Withdrawal of Request for Relief RI-23," dated August 5, 1996.
I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTSO Correspondence Number: NLS2006051 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 Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None PROCEDURE 0.42 REVISION 19 PAGE 20 OF 27