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MONTHYEARML0622205922006-08-14014 August 2006 Request for Additional Information - Risk-Informed Inservice Inspection Relief Request Fourth 10-Year Inservice Inspection Program Relief Request No. NLS2006015 Project stage: RAI ML0628500512006-10-23023 October 2006 Risk-Informed Inservice Inspection Program for Fourth 10-Year Interval; Relief Request No. RI-34 Project stage: Other ML0630402412006-11-0303 November 2006 Correction to and Clarification on Safety Evaluation - Risk Informed Inservice Inspection Program for the Fourth 10-Year Interval; Relief Request No. RI-34 Project stage: Approval 2006-11-03
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Category:Code Relief or Alternative
MONTHYEARML24117A2482024-05-0707 May 2024 Authorization and Safety Evaluation for Relief Request No. RC3-02 ML24033A3092024-02-12012 February 2024 Summary of Regulatory Audit Regarding the Relief Request RC3-02 Regarding Drywell Head Bolting ML22111A1382022-05-13013 May 2022 Proposed Inservice Testing Alternative RS-01, Revision 0 NLS2020053, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI, Relief Request RR5-042020-08-26026 August 2020 Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI, Relief Request RR5-04 NLS2019034, 10 CFR 50.55a Relief Request RP5-02 and RI5-02, Revision 22019-06-28028 June 2019 10 CFR 50.55a Relief Request RP5-02 and RI5-02, Revision 2 ML19092A1402019-04-29029 April 2019 Proposed Inservice Inspection Alternative PR5-02 NLS2018029, Response to Nuclear Regulatory Commission Request for Additional Information for Relief Request RR5-032018-05-16016 May 2018 Response to Nuclear Regulatory Commission Request for Additional Information for Relief Request RR5-03 NLS2017032, 10 CFR 50.55a Request Number RI-21, Revision 12017-03-29029 March 2017 10 CFR 50.55a Request Number RI-21, Revision 1 ML16034A4792016-02-17017 February 2016 Request for Relief RI5-02, Alternative to Use Boiling Water Reactor Vessel and Internals Project Guidelines in Lieu of Specific ASME Code Requirements ML16014A1742016-02-12012 February 2016 Request for Relief RP-01 Through RP-09, RV-01 Through RV-05, and RG-01 Alternative to ASME OM Code Requirements for Inservice Testing for the Fifth Ten-Year Program Interval (CAC Nos. MF5911, MF5913, MF5914, MF5915, MF5916, Etc.) ML16034A3032016-02-12012 February 2016 Request for Relief RC3-01 for Alignment of Inservice Inspection and Containment Inservice Inspection (CAC No. MF6333 ML15134A2422015-05-20020 May 2015 Relief Request RI-08, Revision 0, Relief from Reactor Vessel Nozzle-to-Vessel Shell Welds and Nozzle Inner Radius Sections, for the Fourth 10-Year Inservice Inspection Interval ML12313A1112013-01-22022 January 2013 Relief Request RI-07 from ASME Code Requirements for Residual Heat Removal Shell Circumferential and Nozzle to Head Welds, Fourth 4th 10-Year Inservice Inspection Interval ML12233A1762012-08-28028 August 2012 Relief Request Nos. RV-07, Revision 0, and RV-01, Revision for Fourth 10-Day Inservice Inspection Interval Regarding Weld Overlay Repair NLS2011085, Relief Request from Certain Inservice Testing Code Requirements2011-08-24024 August 2011 Relief Request from Certain Inservice Testing Code Requirements ML1101205402011-02-18018 February 2011 Relief Request RI-36 for Alternative Weld Overlay Repairs for the Fourth 10-Year Inservice Inspection Interval ML1022204492010-10-0808 October 2010 Request for Relief No. RI-04 for the Fourth 10-Year Inservice Inspection Interval Regarding Inspection of Reactor Vessel Nozzle-to-Vessel Shell Welds ML1009703402010-04-26026 April 2010 Relief, Relief Request No. RV-06 from Certain Inservice Testing Requirements Related to Valves in the Control Rod Drive System, for Fourth 10-Year IST Interval NLS2010013, Request Relief from Certain Inservice Inspection (ISI) Code Requirements2010-02-0505 February 2010 Request Relief from Certain Inservice Inspection (ISI) Code Requirements NLS2010014, Request Relief from Certain Inservice Inspection Code Requirements2010-02-0505 February 2010 Request Relief from Certain Inservice Inspection Code Requirements NLS2009038, Relief Request from Certain Inservice Test Code Requirements, RV-06, Revision 02009-06-18018 June 2009 Relief Request from Certain Inservice Test Code Requirements, RV-06, Revision 0 ML0821304832008-08-15015 August 2008 Request for Relief No. Ri - 35 for Fourth Year Inservice Inspection Interval Regarding Weld Overlay Repair ML0802302882008-02-0606 February 2008 Request for Relief No. RI-29, Revision 1, for Fourth 10-Year Inservice Inspection Volumetric Examination of Reactor Pressure Vessel Circumferential Shell Welds ML0631802502006-12-0505 December 2006 Request for Relief from the Requirements of the American Society of Mechanical Engineers Boiler and Vessel Code, Relief Request No. RI-06, Revision 3, for Weld HMC-BB-1 ML0630402412006-11-0303 November 2006 Correction to and Clarification on Safety Evaluation - Risk Informed Inservice Inspection Program for the Fourth 10-Year Interval; Relief Request No. RI-34 ML0628500512006-10-23023 October 2006 Risk-Informed Inservice Inspection Program for Fourth 10-Year Interval; Relief Request No. RI-34 ML0626202782006-10-13013 October 2006 Fourth 10-year Interval Inservice Inspection Request for Relief No. RI-15, Examination of Peripheral Control Rod Drive Housing Welds ML0625400642006-10-11011 October 2006 Fourth 10-Year Interval Inservice Inspection Request for Relief RI-02 ML0622601952006-10-0202 October 2006 Fourth 10-Year Interval Inservice Inspection Request for Relief No. PR-02 ML0622602172006-10-0202 October 2006 Fourth 10-Year Interval Inservice Inspection Request for Relief No. PR-06 ML0622602202006-10-0202 October 2006 Fourth 10-Year Interval Inservice Inspection Request for Relief No. PR-11 ML0622602032006-10-0202 October 2006 Fourth 10-Year Interval Inservice Inspection Request for Relief No. PR-04 ML0623405482006-09-0808 September 2006 Relief, Request for Relief No. RI-13 Fourth 10-Year Interval Inservice Inspection ML0405603182004-02-25025 February 2004 Code Relief-RP-06-IST, Core Spray Pump CS-P-B, MB6821 NLS2003120, Inservice Testing Program Relief Request RP-06, Revision 22003-11-25025 November 2003 Inservice Testing Program Relief Request RP-06, Revision 2 ML0309003842003-03-31031 March 2003 Relief, Inservice Testing of All Pumps as Required by Asme/Ansi OMA-1988, Part 6, Paragraph 6.1, MB6822 2024-05-07
[Table view] Category:Letter
MONTHYEARML24227A0822024-09-0303 September 2024 Summary of Regulatory Audit in Support of License Amendment Request to Modify the High Pressure Coolant Injection Low Flow Value IR 05000298/20240052024-08-22022 August 2024 Updated Inspection Plan for Cooper Nuclear Station (Report 05000298/2024005) IR 05000298/20240022024-07-25025 July 2024 Integrated Inspection Report 05000298/2024002 ML24183A1722024-07-17017 July 2024 Issuance of Amendment No. 277 to Adopt TSTF-374, Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil ML24197A1462024-07-15015 July 2024 NRC Region IV Ltr to Cooper Nuclear Station Re FEMA Level 1 Finding IR 05000298/20243012024-07-12012 July 2024 NRC Examination Report 05000298/2024301 ML24134A1782024-07-0303 July 2024 Issuance of Amendment No. 276 Revision to Technical Specification 3.8.3, Diesel Fuel Oil, Lube Oil and Starting Air, to Allow for Cleaning, Inspection and Any Needed Repairs During Refuel Outage 33 ML24197A0682024-06-24024 June 2024 FEMA Ltr to Missouri State Emergency Management Agency - Level 1 Finding, 24 June 2024 ML24192A0112024-06-13013 June 2024 2024-06-Post Exam Comments IR 05000298/20244012024-06-0404 June 2024 Security Baseline Inspection Report 05000298/2024401 ML24151A1082024-05-30030 May 2024 NRC Initial Operator Licensing Examination Approval 05000298/2024301 ML24137A0942024-05-17017 May 2024 Regulatory Audit Plan in Support of License Amendment Request to Modify Allowable Value Regarding Technical Specification for High Pressure Coolant Injection Pump Discharge Low Flow IR 05000298/20240012024-05-0303 May 2024 Integrated Inspection Report 05000298/2024001 ML24129A0952024-04-25025 April 2024 Preparation and Scheduling of Operator Licensing Examinations IR 05000298/20240102024-04-24024 April 2024 Comprehensive Engineering Team Inspection Report 05000298/2024010 ML24096A1202024-04-0505 April 2024 Issuance of Amendment No. 275 Revision to Technical Specification 3.3.1.1 (Emergency Circumstances) ML24093A2282024-04-0202 April 2024 Notice of Enforcement Discretion for Cooper Nuclear Station IR 05000298/20240902024-04-0101 April 2024 – Notice of Violation, NRC Inspection Report 05000298/2024090 IR 05000298/20230062024-02-28028 February 2024 Annual Assessment Letter for Cooper Nuclear Station - Report 05000298/2023006 IR 05000298/20230042024-02-12012 February 2024 Integrated Inspection Report 05000298/2023004 ML24033A3092024-02-12012 February 2024 Summary of Regulatory Audit Regarding the Relief Request RC3-02 Regarding Drywell Head Bolting IR 05000298/20230122024-02-12012 February 2024 NRC Inspection Report 05000298/2023012 ML23334A2012024-01-0303 January 2024 Issuance of Amendment No. 274 Revision to Technical Specifications to Adopt TSTF-551, Revision 3, Revise Secondary Containment Surveillance Requirements ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23311A1122023-11-0909 November 2023 Project Manager Assignment IR 05000298/20230032023-11-0202 November 2023 Integrated Inspection Report 05000298/2023003 IR 05000298/20234012023-11-0101 November 2023 Cyber Security Report 05000298/2023401 Public ML23264A8052023-10-11011 October 2023 Issuance of Amendment No. 273 Revision to Technical Specifications to Adopt TSTF-580, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling ML23233A1882023-09-0505 September 2023 Regulatory Audit Plan in Support of Relief Request RC3-02 Regarding Drywell Head Bolting IR 05000298/20230052023-08-21021 August 2023 Updated Inspection Plan for Cooper Nuclear Station (Report 05000298/2023005)- Mid Cycle Letter IR 05000298/20230022023-08-0808 August 2023 Integrated Inspection Report 05000298/2023002 IR 05000298/20234022023-08-0303 August 2023 NRC Security Inspection Report 05000298/2023402 ML23214A2742023-08-0303 August 2023 Nuclear Station - Notification of Inspection (NRC Inspection Report 05000298/2023004) and Request for Information IR 05000298/20234202023-08-0101 August 2023 Security Baseline Inspection Report 05000298/2023420 ML23173A0862023-06-26026 June 2023 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000298/2023401 IR 05000298/20230102023-05-17017 May 2023 Biennial Problem Identification and Resolution Inspection Report 05000298/2023010 IR 05000298/20234032023-05-0404 May 2023 Security Baseline Inspection Report 05000298/2023403 ML23129A2822023-04-20020 April 2023 Submittal of Revision 31 to Updated Safety Analysis Report ML23102A0282023-04-19019 April 2023 U.S. Nuclear Regulatory Commission Presentation at the May 8, 2023, Brownville Village Meeting IR 05000298/20230012023-04-17017 April 2023 Integrated Inspection Report 05000298/2023001 ML23060A1582023-03-0808 March 2023 Design Basis Assurance Inspection (Programs) Inspection Report 05000298/2023001 IR 05000298/20220062023-03-0101 March 2023 Annual Assessment Letter for Cooper Nuclear Station Report 05000298/2022006 ML23041A1622023-02-10010 February 2023 Licensed Operator Positive Fitness-for-Duty Test Request for Additional Information IR 05000298/20220042023-01-30030 January 2023 Integrated Inspection Report 05000298/2022004 IR 05000298/20220112022-12-23023 December 2022 License Renewal Phase 4 Inspection Report 05000298/2022011 ML22286A2072022-11-30030 November 2022 Issuance of Amendment No. 272 Revision to Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements IR 05000298/20220032022-10-27027 October 2022 Integrated Inspection Report 05000298/2022003 ML22304A0052022-10-26026 October 2022 Surveillance Capsule Location (Re-insertion Into the Reactor Vessel) IR 05000298/20223022022-10-20020 October 2022 NRC Initial Operator Licensing Examination Approval 05000298/2022302 ML22276A1562022-10-0505 October 2022 Notification of Commercial Grade Dedication Inspection 05000298/2023011 and Request for Information 2024-09-03
[Table view] Category:Safety Evaluation
MONTHYEARML24183A1722024-07-17017 July 2024 Issuance of Amendment No. 277 to Adopt TSTF-374, Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil ML24134A1782024-07-0303 July 2024 Issuance of Amendment No. 276 Revision to Technical Specification 3.8.3, Diesel Fuel Oil, Lube Oil and Starting Air, to Allow for Cleaning, Inspection and Any Needed Repairs During Refuel Outage 33 ML24117A2482024-05-0707 May 2024 Authorization and Safety Evaluation for Relief Request No. RC3-02 ML24096A1202024-04-0505 April 2024 Issuance of Amendment No. 275 Revision to Technical Specification 3.3.1.1 (Emergency Circumstances) ML23334A2012024-01-0303 January 2024 Issuance of Amendment No. 274 Revision to Technical Specifications to Adopt TSTF-551, Revision 3, Revise Secondary Containment Surveillance Requirements ML23264A8052023-10-11011 October 2023 Issuance of Amendment No. 273 Revision to Technical Specifications to Adopt TSTF-580, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling ML22286A2072022-11-30030 November 2022 Issuance of Amendment No. 272 Revision to Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements ML22200A2772022-07-21021 July 2022 Correction to Proposed Inservice Testing Alternative RS-01, Revision of Error in Safety Evaluation ML22152A1232022-07-18018 July 2022 Issuance of Amendment No. 271 Request for Exception from Certain Primary Containment Leak Rate Testing Requirements ML22140A1612022-06-0808 June 2022 Proposed Inservice Inspection Alternative RR5-01 Revision 1 ML22111A1382022-05-13013 May 2022 Proposed Inservice Testing Alternative RS-01, Revision 0 ML22045A0012022-03-31031 March 2022 Proposed Inservice Inspection Alternative RI5- 02 Revision 3 ML21340A2362021-12-20020 December 2021 Issuance of Amendment No. 270 Adoption of Technical Specifications Task Force Traveler TSTF-582, Revision 0, RPV WIC Enhancements ML21040A3002021-03-29029 March 2021 Issuance of Amendment No. 269 to Revise Emergency Action Levels to a Scheme Based on NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors ML20314A2352020-12-0202 December 2020 Issuance of Amendment No. 268 Revision to Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, Using the Consolidated Line Item Improvement Process ML20282A1762020-10-22022 October 2020 Issuance of Amendment No. 267 Regarding Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-529, Revision 4, Clarify Use and Application Rules ML20255A2172020-09-15015 September 2020 Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI ML20077L3392020-03-19019 March 2020 Proposed Inservice Inspection Alternatives RP5-02 and RI5-02 ML19352G1942020-01-28028 January 2020 Issuance of Amendment No. 264 Elimination of Technical Specification Requirements for Hydrogen/Oxygen Monitors Using the Consolidated Line Item Improvement Process ML19238A0072019-10-30030 October 2019 Issuance of Amendment No. 263 Adoption of TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation ML19079A0702019-05-0707 May 2019 Safety Evaluation Regarding Implementation of Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Related to Order EA-13-109 (CAC No. MF4384; EPID No. L-2014-JLD-0046) ML19092A1402019-04-29029 April 2019 Proposed Inservice Inspection Alternative PR5-02 ML18348B1032019-02-21021 February 2019 Issuance of Amendment No. 262 Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control ML18218A4832018-09-0606 September 2018 Issuance of Amendment No. 261 Safety Limit Minimum Critical Power Ratio ML18186A5492018-08-0101 August 2018 Issuance of Amendment No.260 Revision to Technical Specifications to Adopt (TSTF) Traveler TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (CAC No. MG0138; EPID L-2017-LLA-0290) ML18183A3252018-07-31031 July 2018 Requests for Relief Associated with - the Fifth 10-year Inservice Inspection Interval Program (CAC Nos. MG0175 Through MG0179; Epids L-2017-LLR-0062 Through L-2017-LLR-0066) ML18064A1022018-03-22022 March 2018 Request No. RI-21, Revision 1 - Request for Relief Concerning Examinations for the Fourth 10-Year Inservice Inspection Interval (CAC No. MF9623; EPID L-2017-LLR-0026) ML17226A0322017-09-20020 September 2017 Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 ML17144A0822017-06-20020 June 2017 Issuance of Amendment No. 259 Adoption of TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing ML17061A0502017-03-31031 March 2017 Issuance of Amendment No. 258 Adoption of TSTF-425, Revision 3, ML16272A1372016-10-17017 October 2016 Issuance of Amendment No. 257 Revision of Technical Specifications - Safety Limit Minimum Critical Power Ratio ML16158A0222016-07-25025 July 2016 Issuance of Amendment No. 256 to Relocate the Pressure-Temperature Curves to a Pressure-Temperature Limits Report ML16119A4332016-07-25025 July 2016 Issuance of Amendment No. 254 Adoption of Technical Specification Task Force Change Traveler TSFT-535, Revision 0 ML16146A7492016-07-25025 July 2016 Issuance of Amendment No. 255 Replacement of Technical Specification Figure 4.1-1 with Text ML16042A3262016-02-24024 February 2016 Request for Relief RR5-01, Alternative Weld Overlay Repair for a Dissimilar Metal Weld Joining Nozzle to Control Rod Drive End Cap in Lieu of Specific ASME Boiler and Pressure Vessel Code Requirements ML16048A3402016-02-24024 February 2016 Request for Inservice Inspection Program Alternative RP5-01 for Implementation of Code Case N-795 ML16034A4792016-02-17017 February 2016 Request for Relief RI5-02, Alternative to Use Boiling Water Reactor Vessel and Internals Project Guidelines in Lieu of Specific ASME Code Requirements ML16034A3032016-02-12012 February 2016 Request for Relief RC3-01 for Alignment of Inservice Inspection and Containment Inservice Inspection (CAC No. MF6333 ML16014A1742016-02-12012 February 2016 Request for Relief RP-01 Through RP-09, RV-01 Through RV-05, and RG-01 Alternative to ASME OM Code Requirements for Inservice Testing for the Fifth Ten-Year Program Interval (CAC Nos. MF5911, MF5913, MF5914, MF5915, MF5916, Etc.) ML15343A3012016-01-22022 January 2016 Issuance of Amendment No. 253 to Technical Specifications to Add Residual Heat Removal System Containment Spray Function ML15216A2592015-08-27027 August 2015 Issuance of Amendment No. 252, Revise Technical Specification 3.5.2, ECCS - Shutdown, to Delete Condensate Storage Tank as Alternate Source of Makeup Water ML15168A1712015-07-14014 July 2015 Issuance of Amendment No. 251, Request to Move Linear Heat Generation Rate (LHGR) and Single Loop Operation LHGR Limit from Technical Requirements Manual to Technical Specifications ML15135A0052015-05-29029 May 2015 Issuance of Amendment No. 250, Adopt Technical Specification Task Force (TSTF) Traveler TSTF-413, Elimination of Requirements for a Post Accident Sampling System (PASS) ML15134A2422015-05-20020 May 2015 Relief Request RI-08, Revision 0, Relief from Reactor Vessel Nozzle-to-Vessel Shell Welds and Nozzle Inner Radius Sections, for the Fourth 10-Year Inservice Inspection Interval ML14365A0932015-01-13013 January 2015 Correction to Safety Evaluation Dated December 12, 2014, Regarding Amendment No. 249, Request to Revise Operating License Condition Related to Cyber Security Plan Milestone 8 Full Implementation Date ML14323A6442014-12-12012 December 2014 Issuance of Amendment No. 249, Request to Revise Operating License Conditions Related to Cyber Security Plan Milestone 8 Full Implementation Date ML14190A0042014-07-25025 July 2014 Redacted, Review of License Renewal Commitment Review Related to Core Plate Hold Down Bolt Inspection Plan and Analysis (TAC Nos. ME9550 and MF3557) ML14055A0232014-04-29029 April 2014 Issuance of Amendment No. 248, Adopt National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for LWR Electric Generating Plants ML13263A1532013-10-0707 October 2013 Correction to Amendment No. 247 Issued 9/12/13, Revise License Condition 2.E to Require All License Renewal Commitments Will Be Incorporated Into the Updated Safety Analysis Report ML13191A1052013-09-12012 September 2013 Issuance of Amendment No. 247, Revise License Condition 2.E to Require All License Renewal Commitments Will Be Incorporated Into the Updated Safety Analysis Report 2024-07-03
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November 3, 2006 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - CORRECTIONS TO AND CLARIFICATION IN THE SAFETY EVALUATION RE: RISK-INFORMED INSERVICE INSPECTION PROGRAM FOR THE FOURTH 10-YEAR INTERVAL; RELIEF REQUEST NO. RI-34 (TAC NO. MD0283)
Dear Mr. Edington:
By letter dated October 23, 2006, the Nuclear Regulatory Commission (NRC) authorized the proposed alternative for the fourth 10-year inservice interval for the Cooper Nuclear Station.
Upon review of the October 23, 2006, document, you noted that certain areas of the safety evaluation need clarification and corrections. The NRC agrees with your observations.
The NRC is issuing the corrected safety evaluation for replacement. The changes are marked with revision bars in the margin.
We regret any inconvenience this may have caused.
Sincerely,
/RA/
Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Corrected Safety Evaluation cc w/encl: See next page
ML063040241 OFFICE NRR/LPLIV/PM NRR/LPLIV/LA NRR/LPLIV/BC NAME BVaidya LFeizollahi DTerao DATE 11/2/06 11/2/06 11/3/06 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR RELIEF RI-34 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION
By letter dated February 23, 2006, and supplemented by a request for additional information response dated August 24, 2006, Nebraska Public Power District (the licensee) requested, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(5)(iii), that the Nuclear Regulatory Commission (NRC) approve Relief Request RI-34, to extend the Risk-Informed Inservice Inspection (RI-ISI) Program Plan for Cooper Nuclear Station (CNS) to the fourth 10-year inservice inspection (ISI) interval. The CNS RI-ISI program was initially submitted to the NRC staff in a letter dated March 11, 2004, during the third inspection period of the third 10-year ISI interval, and supplemented in letters dated May 20 and July 29, 2004. The CNS RI-ISI program was reviewed and approved by the NRC for use in the third 10-year ISI interval in a letter dated December 9, 2004.
The licensees submittal proposes to extend the same RI-ISI program from the third 10-year ISI interval to the fourth 10-year ISI interval.
2.0 BACKGROUND
AND REGULATORY EVALUATION Title 10 of the Code of Federal Regulations, paragraph 50.55a(g) specifies that ISI of nuclear power plant components shall be performed in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),
Section XI, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Paragraph 50.55a(a)(3) of 10 CFR states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The licensees RI-ISI program was developed in accordance with the methodology contained in the Electric Power Research Institutes (EPRIs) report EPRI Topical Report (TR)-112657, Revision B-A, which was reviewed and approved by the NRC staff, with one exception, as l
described in the licensee's submission dated February 23, 2006. The CNS RI-ISI program is l an alternative pursuant to 10 CFR 50.55a(a)(3)(i). In its letter dated February 23, 2006, the licensee requested NRC's authorization to utilize the RI-ISI program previously approved for use in the third 10-year ISI interval, in the fourth 10-year ISI interval at CNS. The scope of the RI-ISI program is limited to the inspection of ASME Code Class 1 and Class 2 piping (Categories B-F, B-J, and C-F-2 welds).
3.0 TECHNICAL EVALUATION
The licensee is requesting relief to use the proposed RI-ISI program plan in the fourth 10-year ISI interval instead of the ASME Code,Section XI, program. An acceptable RI-ISI program plan is expected to meet the five key principles discussed in Regulatory Guide (RG) 1.178, Standard Review Plan (SRP) 3.9.8, and EPRI TR-112657, as stated below:
- 1. The proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change.
- 2. The proposed change is consistent with the defense-in-depth philosophy.
- 3. The proposed change maintains sufficient safety margins.
- 4. When proposed changes result in an increase in Core Damage Frequency (CDF) or risk, the increases should be small and consistent with the intent of the Commissions Safety Goal Policy Statement.
- 5. The impact of the proposed change should be monitored by using performance measurement strategies.
The first principle is met in this relief request because an alternative ISI program may be authorized pursuant to 10 CFR 50.55a(3)(i) and, therefore, an exemption request is not required.
The second and third principles require assurance that the alternative program is consistent with the defense-in-depth philosophy and that sufficient safety margins are maintained, respectively. Assurance that the second and third principles are met is based on the application of the approved methodology and not on the particular inspection locations selected.
In accordance with the guidance provided in EPRI TR-112657 and SRP 3.9.8, the licensee provided the results of an engineering analysis of the proposed changes, using a combination of traditional engineering analysis and supporting insights from the probabilistic risk assessment (PRA). The licensee performed an evaluation to determine susceptibility of components (i.e., a piping weld) to a particular degradation mechanism that may be a precursor to leak or rupture and then performed an independent assessment of the consequences of a failure at that location. The results of this analysis ensure that the proposed changes are consistent with the principles of defense-in-depth. Principles of defense-in-depth are met because EPRI TR-112657 methodology requires that the population of welds with high consequences following failure will always have some weld locations inspected regardless of
the failure potential. No changes to the evaluation of design-basis accidents in the final safety analysis report are being made by the RI-ISI process. Therefore, sufficient safety margins will be maintained.
The licensee has provided assurance that the methodology used to develop the fourth 10-year RI-ISI interval program will go unchanged from the methodology approved for use in the third 10-year RI-ISI interval program and, therefore, the second and third principles are met.
The fourth principle requires an estimate of the change in risk, and the change in risk is dependent on the location of inspections in the proposed ISI program compared to the location of inspections that would be inspected using the requirements of ASME Code,Section XI.
As required by Section 3.7 of EPRI TR-112657, the licensee evaluated the change in risk expected from replacing the current ISI program with the RI-ISI program. The calculations estimated the change in risk due to removing locations and adding locations to the inspection program. The expected change in risk was quantitatively evaluated using the "Simplified Risk Quantification Method" described in Section 3.7 of EPRI TR-112657. For high-consequence category segments, the licensee used the conditional core damage probability (CCDP) and conditional large early release probability (CLERP) based on the highest estimated CCDP and CLERP. For medium-consequence category segments, bounding estimates of CCDP and CLERP were used. The licensee estimated the change in risk using bounding pipe failure rates from the EPRI methodology. The licensee performed its bounding analysis with and without taking credit for an increased probability of detection (POD). The aggregate change in risk estimates are provided in the following table:
Change In CDF Change In Large Early Release Frequency (LERF)
With Increased POD Without Increased With Increased POD Without Increased POD POD 1.26E-09/year 1.32E-09/year 1.26E-10/year 1.32E-10/year l The staff finds the licensee's process to evaluate and bound the potential change in risk reasonable, because it (1) accounts for the change in the number and location of elements inspected, (2) recognizes the differences in degradation mechanisms related to failure likelihood, and (3) considers the synergistic effects of multiple degradation mechanisms within the same piping segment. System level and aggregate estimates of the changes in CDF and LERF are less than the corresponding guideline values in EPRI TR-112657. The staff finds that redistributing the welds to be inspected with consideration of the safety significance of the segments provides assurance that segments whose failure has a significant impact on plant risk receive an acceptable and often improved level of inspection. The NRC staff concludes that the implementation of the RI-ISI program will have a small impact on risk consistent with the guidelines of EPRI TR-112657; therefore, the fourth principle is met.
Implementation and performance monitoring strategies require careful consideration by the licensee and are addressed in Element 3 of EPRI TR-112657 and Section 3.9.8 of the SRP.
The objective of Element 3 is to assess performance of the affected piping systems under the
proposed RI-ISI program by utilizing monitoring strategies that confirm the assumptions and analyses used in the development of the RI-ISI program. Pursuant to 10 CFR 50.55a(a)(3)(i), a proposed alternative in this case the implementation of the RI-ISI program, including inspection scope, examination methods, and methods of evaluation of examination results must provide an acceptable level of quality and safety.
The licensee stated that, upon approval of the RI-ISI program, procedures that comply with EPRI TR-112657 guidelines will be prepared to implement and monitor the RI-ISI program. The licensee stated in its letter dated February 23, 2006, that the applicable aspects of the ASME Code not affected by the proposed RI-ISI program would be retained.
The licensee indicated in Section 4 of its letter dated February 23, 2006, that the RI-ISI program is a living program and its implementation will require feedback of new relevant information to ensure the appropriate identification of safety-significant piping locations. The licensee also stated that, as a minimum, risk ranking of piping segments will be reviewed and adjusted on an ASME period basis, and that significant changes may require more frequent adjustment as directed by NRC bulletin or generic letter requirements, or by industry and plant-specific feedback. This periodic review and adjustment of the risk-ranking of segments ensures that changes to the PRA, which the licensee will make to incorporate the peer review results, will also be incorporated in the RI-ISI program as necessary.
The licensee addressed additional examinations in Section 3.5.1 of its letter dated February 23, 2006, which states that examinations performed that reveal flaws or relevant conditions exceeding the applicable acceptance standards shall be extended to include additional examinations. These additional examinations shall include piping structural elements with the same postulated failure mode and the same or higher failure potential. Additional examinations will be performed on these elements up to a number equivalent to the number of elements with the same postulated failure mode originally scheduled for that fuel cycle. If the additional required examinations reveal flaws or relevant conditions exceeding the acceptance standards, the examinations shall be further extended to include all elements subject to the same failure mechanism, throughout the scope of the program, during the same outage.
The fifth principle states that risk-informed applications should include performance monitoring and feedback provisions. The staff finds that the proposed process for RI-ISI program implementation, monitoring, feedback, and updating meets the guidelines given in RG 1.174. Therefore, the licensee's proposed process for program implementation, monitoring, feedback, and updating is acceptable.
Based on the above discussion, the staff finds that the five key principles of risk-informed decision making are ensured by the licensees proposed fourth 10-year ISI interval RI-ISI program.
4.0 CONCLUSION
Based on the information provided in the licensees submittals, the NRC staff has determined l that the proposed alternative provides an acceptable level of quality and safety. Therefore, the l proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 10-year ISI interval at CNS.
All other ASME Code,Section XI, requirements for which relief was not specifically requested and authorized herein by the NRC staff remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributors: G. Georgiev J. Walker Date: October 23, 2006
Cooper Nuclear Station cc:
Mr. Ronald D. Asche Mr. H. Floyd Gilzow President and Chief Executive Officer Deputy Director for Policy Nebraska Public Power District Missouri Department of Natural Resources 1414 15th Street P. O. Box 176 Columbus, NE 68601 Jefferson City, MO 65102-0176 Mr. Gene Mace Senior Resident Inspector Nuclear Asset Manager U.S. Nuclear Regulatory Commission Nebraska Public Power District P. O. Box 218 P.O. Box 98 Brownville, NE 68321 Brownville, NE 68321 Regional Administrator, Region IV Mr. John C. McClure U.S. Nuclear Regulatory Commission Vice President and General Counsel 611 Ryan Plaza Drive, Suite 400 Nebraska Public Power District Arlington, TX 76011 P. O. Box 499 Columbus, NE 68602-0499 Director, Missouri State Emergency Management Agency Mr. Paul V. Fleming P. O. Box 116 Licensing Manager Jefferson City, MO 65102-0116 Nebraska Public Power District P.O. Box 98 Chief, Radiation and Asbestos Brownville, NE 68321 Control Section Kansas Department of Health Mr. Michael J. Linder, Director and Environment Nebraska Department of Environmental Bureau of Air and Radiation Quality 1000 SW Jackson P. O. Box 98922 Suite 310 Lincoln, NE 68509-8922 Topeka, KS 66612-1366 Chairman Mr. Donald A. Flater Nemaha County Board of Commissioners Radiation Control Program Director Nemaha County Courthouse Bureau of Radiological Health 1824 N Street Iowa Department of Public Health Auburn, NE 68305 Lucas State Office Building, 5th Floor 321 East 12th Street Ms. Julia Schmitt, Manager Des Moines, IA 50319 Radiation Control Program Nebraska Health & Human Services R & L Mr. Daniel K. McGhee Public Health Assurance Bureau of Radiological Health 301 Centennial Mall, South Iowa Department of Public Health P.O. Box 95007 Lucas State Office Building, 5th Floor Lincoln, NE 68509-5007 321 East 12th Street Des Moines, IA 50319 October 2006
Cooper Nuclear Station Mr. Keith G. Henke, Planner Division of Community and Public Health Office of Emergency Coordination 930 Wildwood P.O. Box 570 Jefferson City, MO 65102 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. John F. McCann, Director Licensing, Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601-1813 October 2006