ML19196A345: Difference between revisions

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{{#Wiki_filter:Nebraska Public Power DistrictCooper Nuclear StationJuly 18, 2019 1
{{#Wiki_filter:Nebraska Public Power District Cooper Nuclear Station July 18, 2019 1
Introductions  
 
-Dave Van Der KampNPPD DiscussionQuestionsClosing -Dave Van Der Kamp 2
Introductions - Dave Van Der Kamp NPPD Discussion Questions Closing - Dave Van Der Kamp 2
Dave Van Der KampLicensing Manager 3
 
Tom RobinsonEngineering Programs & Components Engineer 4
Dave Van Der Kamp Licensing Manager 3
Appendix J Frequency RequirementsCNS TS 5.5.12 requires Appendix J Program to be in accordance with RG 1.163RG 1.163 approves NEI 94-01 as an acceptable means of demonstrating compliance with Appendix J requirements 5
 
NEI 94-01 sections 10.2.1.3 and 10.2.3.3 have the following Requirements: If penetration (type B) or valve (type C) is replaced or engineering judgement determines that modification of penetration or valve has invalidated penetration's or valve's performance history, then frequency shall be in accordance with 10.2.1.2 (type B) or 10.2.3.2 (type C). Sections 10.2.1.2 (type B) or 10.2.3.2 (type C) Frequency Requirements:At least once every 30 months 6
Tom Robinson Engineering Programs &
Background CNS design contains two RHR HX relief valves that discharge back to TorusValves have safety function in the open (overpressurization) and closed (primary containment) positionsWithin scope of IST Program [10CFR50.55a] and 10CFR 50 Appendix J 7
Components Engineer 4
CNS Current PracticePretested new and/or rebuilt valve assemblies typically utilized to satisfy IST ProgramHistorical results for Appendix J as found and as left testing on testable discharge flange and valve have been excellent 8
 
Current IssueEven though IST Program would allow IST testing of the RVs to be less frequent than every outage, replacing relief valves with pretested new and/or rebuilt valves causes frequency of performing Appendix J testing to be performed every outageResults in additional Appendix J testing, draining of the system, removal of the RVs, etc.
Appendix J Frequency Requirements CNS TS 5.5.12 requires Appendix J Program to be in accordance with RG 1.163 RG 1.163 approves NEI 94-01 as an acceptable means of demonstrating compliance with Appendix J requirements 5
9 ProcessSince NEI 94
 
-01 is endorsed by RG 1.163, is it appropriate to evaluate the alignment of App. J and IST testing frequencies as an acceptable alternative to the RG orIs an exemption request per 10 CFR 50.12 the appropriate process for aligning Appendix J testing frequency to allow it to be performed at the same frequency as IST required testing.
NEI 94-01 sections 10.2.1.3 and 10.2.3.3 have the following Requirements:
10 Dave Van Der KampLicensing Manager 11 Any further questions or comments 12 Dave Van Der KampLicensing Manager 13}}
If penetration (type B) or valve (type C) is replaced or engineering judgement determines that modification of penetration or valve has invalidated penetration's or valve's performance history, then frequency shall be in accordance with 10.2.1.2 (type B) or 10.2.3.2 (type C).
Sections 10.2.1.2 (type B) or 10.2.3.2 (type C)
Frequency Requirements:
At least once every 30 months 6
 
===Background===
CNS design contains two RHR HX relief valves that discharge back to Torus Valves have safety function in the open (overpressurization) and closed (primary containment) positions Within scope of IST Program [10CFR50.55a] and 10CFR 50 Appendix J 7
 
CNS Current Practice Pretested new and/or rebuilt valve assemblies typically utilized to satisfy IST Program Historical results for Appendix J as found and as left testing on testable discharge flange and valve have been excellent 8
 
Current Issue Even though IST Program would allow IST testing of the RVs to be less frequent than every outage, replacing relief valves with pretested new and/or rebuilt valves causes frequency of performing Appendix J testing to be performed every outage Results in additional Appendix J testing, draining of the system, removal of the RVs, etc.
9
 
Process Since NEI 94-01 is endorsed by RG 1.163, is it appropriate to evaluate the alignment of App. J and IST testing frequencies as an acceptable alternative to the RG or Is an exemption request per 10 CFR 50.12 the appropriate process for aligning Appendix J testing frequency to allow it to be performed at the same frequency as IST required testing.
10
 
Dave Van Der Kamp Licensing Manager 11
 
Any further questions or comments 12
 
Dave Van Der Kamp Licensing Manager 13}}

Latest revision as of 16:35, 19 October 2019

July 18, 2019 Public Teleconference Slides Appendix J Exemption Request Presubmittal Teleconference
ML19196A345
Person / Time
Site: Cooper Entergy icon.png
Issue date: 07/18/2019
From: Thomas Wengert
Plant Licensing Branch IV
To: Dent J
Nebraska Public Power District (NPPD)
Wengert T, NRR/DORL/LPLIV, 415-4037
References
Download: ML19196A345 (13)
v • d • e


Text

Nebraska Public Power District Cooper Nuclear Station July 18, 2019 1

Introductions - Dave Van Der Kamp NPPD Discussion Questions Closing - Dave Van Der Kamp 2

Dave Van Der Kamp Licensing Manager 3

Tom Robinson Engineering Programs &

Components Engineer 4

Appendix J Frequency Requirements CNS TS 5.5.12 requires Appendix J Program to be in accordance with RG 1.163 RG 1.163 approves NEI 94-01 as an acceptable means of demonstrating compliance with Appendix J requirements 5

NEI 94-01 sections 10.2.1.3 and 10.2.3.3 have the following Requirements:

If penetration (type B) or valve (type C) is replaced or engineering judgement determines that modification of penetration or valve has invalidated penetration's or valve's performance history, then frequency shall be in accordance with 10.2.1.2 (type B) or 10.2.3.2 (type C).

Sections 10.2.1.2 (type B) or 10.2.3.2 (type C)

Frequency Requirements:

At least once every 30 months 6

Background

CNS design contains two RHR HX relief valves that discharge back to Torus Valves have safety function in the open (overpressurization) and closed (primary containment) positions Within scope of IST Program [10CFR50.55a] and 10CFR 50 Appendix J 7

CNS Current Practice Pretested new and/or rebuilt valve assemblies typically utilized to satisfy IST Program Historical results for Appendix J as found and as left testing on testable discharge flange and valve have been excellent 8

Current Issue Even though IST Program would allow IST testing of the RVs to be less frequent than every outage, replacing relief valves with pretested new and/or rebuilt valves causes frequency of performing Appendix J testing to be performed every outage Results in additional Appendix J testing, draining of the system, removal of the RVs, etc.

9

Process Since NEI 94-01 is endorsed by RG 1.163, is it appropriate to evaluate the alignment of App. J and IST testing frequencies as an acceptable alternative to the RG or Is an exemption request per 10 CFR 50.12 the appropriate process for aligning Appendix J testing frequency to allow it to be performed at the same frequency as IST required testing.

10

Dave Van Der Kamp Licensing Manager 11

Any further questions or comments 12

Dave Van Der Kamp Licensing Manager 13

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