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MONTHYEARNLS2009006, 10 CFR 50.55a Request Number RI-21, Revision 0, and Request Number RI-22, Revision 02009-02-16016 February 2009 10 CFR 50.55a Request Number RI-21, Revision 0, and Request Number RI-22, Revision 0 Project stage: Request ML0909000252009-03-31031 March 2009 Acceptance Review E-Mail, Relief Requests RI-21 and RI-22 to Use Alternative Examination Volume Defined in Code Case N-613-1, Figure 1 Project stage: Acceptance Review ML0920900652009-07-31031 July 2009 Request for Additional Information, Relief Requests RI-21 and RI-22 to Use Alternative Examination Volume Defined in Code Case N-613-1, Figure 1 Project stage: RAI NLS2009072, Response to Request for Additional Information Regarding 10 CFR 50.55a Request RI-21, Revision 0, and Request RI-22, Revision 02009-09-18018 September 2009 Response to Request for Additional Information Regarding 10 CFR 50.55a Request RI-21, Revision 0, and Request RI-22, Revision 0 Project stage: Response to RAI 2009-03-31
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Category:Inservice/Preservice Inspection and Test Report
MONTHYEARML23129A2872022-09-14014 September 2022 Fifth Ten-Year Interval ISI Program and Third Ten-Year Interval Containment Inservice Inspection Program, Revision 4 ML21130A0842021-04-21021 April 2021 Fifth Ten-Year Interval Inservice Inspection Program and Third Ten-Year Interval Containment Inservice Inspection Program, Revision 3 ML21130A0852021-04-21021 April 2021 0 to Updated Final Safety Analysis Report, Appendix J, Inservice Inspection Program NLS2021009, Inservice Inspection OAR-1 Owner'S Activity Report2021-01-21021 January 2021 Inservice Inspection OAR-1 Owner'S Activity Report NLS2019005, Inservice Inspection OAR-1 Owner'S Activity Report2019-02-14014 February 2019 Inservice Inspection OAR-1 Owner'S Activity Report NLS2017071, Inservice Inspection Program Fifth Ten-Year Interval 10 CFR 50.55a Relief Requests2017-08-17017 August 2017 Inservice Inspection Program Fifth Ten-Year Interval 10 CFR 50.55a Relief Requests NLS2017006, Inservice Inspection OAR-1 Owner'S Activity Report2017-02-0202 February 2017 Inservice Inspection OAR-1 Owner'S Activity Report NLS2015003, Inservice Inspection OAR-I Owner'S Activity Report2015-01-28028 January 2015 Inservice Inspection OAR-I Owner'S Activity Report NLS2013031, Inservice Inspection OAR-I Owner'S Activity Report2013-02-27027 February 2013 Inservice Inspection OAR-I Owner'S Activity Report NLS2011082, Inservice Inspection Owner'S Activity Report (OAR-1) Owner'S Activity Report2011-08-0505 August 2011 Inservice Inspection Owner'S Activity Report (OAR-1) Owner'S Activity Report NLS2010016, Inservice Inspection OAR-I Owner'S Activity Report for the Fall 2009 Refueling Outage2010-02-0202 February 2010 Inservice Inspection OAR-I Owner'S Activity Report for the Fall 2009 Refueling Outage NLS2009006, 10 CFR 50.55a Request Number RI-21, Revision 0, and Request Number RI-22, Revision 02009-02-16016 February 2009 10 CFR 50.55a Request Number RI-21, Revision 0, and Request Number RI-22, Revision 0 NLS2008065, Inservice Inspection Summary Report for the Spring 2008 Refueling Outage2008-08-14014 August 2008 Inservice Inspection Summary Report for the Spring 2008 Refueling Outage NLS2008007, Correction to Inservice Inspection Summary Report2008-01-17017 January 2008 Correction to Inservice Inspection Summary Report NLS2007013, Inservice Inspection Summary Report2007-02-20020 February 2007 Inservice Inspection Summary Report NLS2006064, Response to NRC Request for Additional Information Regarding Relief Request RI-13 for the Fourth 10-Year Inservice Inspection Interval Cooper Nuclear Station2006-08-0101 August 2006 Response to NRC Request for Additional Information Regarding Relief Request RI-13 for the Fourth 10-Year Inservice Inspection Interval Cooper Nuclear Station NLS2006015, 10 CFR 50.55a Requests for Fourth Ten-Year Inservice Inspection Interval2006-02-23023 February 2006 10 CFR 50.55a Requests for Fourth Ten-Year Inservice Inspection Interval NLS2005074, Fourth Ten-Year Interval Pump and Valve Inservice Testing Program Relief Requests2005-10-19019 October 2005 Fourth Ten-Year Interval Pump and Valve Inservice Testing Program Relief Requests NLS2005086, Inservice Inspection Relief Requests RI-21, Revision 2, and RI-36 and Withdrawal of Relief Request RI-202005-09-28028 September 2005 Inservice Inspection Relief Requests RI-21, Revision 2, and RI-36 and Withdrawal of Relief Request RI-20 NLS2005049, Inservice Inspection Summary Report2005-05-16016 May 2005 Inservice Inspection Summary Report NLS2004125, Inservice Inspection Relief Request RI-35 Cooper Nuclear Station2004-10-25025 October 2004 Inservice Inspection Relief Request RI-35 Cooper Nuclear Station NLS2004009, Inservice Inspection Relief Requests PR-03, RC-06, RC-07, R1-17, R1-31, R1-32, and R1-332004-02-12012 February 2004 Inservice Inspection Relief Requests PR-03, RC-06, RC-07, R1-17, R1-31, R1-32, and R1-33 NLS2003059, Inservice Testing Program Relief Request RP-06, Revision 12003-09-19019 September 2003 Inservice Testing Program Relief Request RP-06, Revision 1 NLS2003080, Inservice Inspection (ISI) Summary Report for the Spring 2003 Refueling Outage at Cooper Nuclear Station2003-07-21021 July 2003 Inservice Inspection (ISI) Summary Report for the Spring 2003 Refueling Outage at Cooper Nuclear Station NLS2002111, Inservice Testing Program Relief Request RP-06, RP-072002-11-14014 November 2002 Inservice Testing Program Relief Request RP-06, RP-07 NLS2002040, Inservice Inspection Summary Report for Cooper Nuclear Station2002-03-28028 March 2002 Inservice Inspection Summary Report for Cooper Nuclear Station 2022-09-14
[Table view] Category:Letter type:NLS
MONTHYEARNLS2024006, Response to Nuclear Regulatory Commission'S Request for Additional Information for Relief Request RC3-022024-01-25025 January 2024 Response to Nuclear Regulatory Commission'S Request for Additional Information for Relief Request RC3-02 NLS2024007, Emergency Plan Implementing Procedure 5.7.1, Revision 732024-01-16016 January 2024 Emergency Plan Implementing Procedure 5.7.1, Revision 73 NLS2024003, 30 Day Report - Unauthorized Disassembly of Liquid Scintillation Detector2024-01-15015 January 2024 30 Day Report - Unauthorized Disassembly of Liquid Scintillation Detector NLS2024004, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20232024-01-10010 January 2024 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2023 NLS2023053, ISFSI, Supplement to Exemption Request from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-30030 November 2023 ISFSI, Supplement to Exemption Request from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation NLS2023050, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation NLS2023045, Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program2023-11-15015 November 2023 Application to Revise Technical Specifications to Adopt TSTF-374, Revision to Diesel Fuel Oil Testing Program NLS2023051, Response to Nuclear Regulatory Commission Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2023-10-10010 October 2023 Response to Nuclear Regulatory Commission Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2023049, 10 CFR Part 21 Report Regarding HGA Relays2023-09-0606 September 2023 10 CFR Part 21 Report Regarding HGA Relays NLS2023029, License Amendment Request to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks2023-09-0606 September 2023 License Amendment Request to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks NLS2023047, Licensee Guarantees of Payment of Deferred Premiums2023-07-26026 July 2023 Licensee Guarantees of Payment of Deferred Premiums NLS2023033, 10 CFR 50.55a Relief Request RC3-022023-06-27027 June 2023 10 CFR 50.55a Relief Request RC3-02 NLS2023039, Preparation and Scheduling of Operator Licensing Examinations2023-06-0101 June 2023 Preparation and Scheduling of Operator Licensing Examinations NLS2023038, Nebraska Public Power District 2022 Financial Report2023-05-22022 May 2023 Nebraska Public Power District 2022 Financial Report NLS2023031, Annual Radiological Environmental Report2023-05-11011 May 2023 Annual Radiological Environmental Report NLS2023017, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2023-05-0303 May 2023 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2023018, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-0303 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling NLS2023030, Annual Radioactive Effluent Release Report2023-04-27027 April 2023 Annual Radioactive Effluent Release Report NLS2023007, Technical Specification Bases Changes2023-04-17017 April 2023 Technical Specification Bases Changes NLS2023027, Annual Report of Individual Exposure Monitoring2023-04-13013 April 2023 Annual Report of Individual Exposure Monitoring NLS2023021, Quality Assurance Program Changes2023-04-10010 April 2023 Quality Assurance Program Changes NLS2023020, Decommissioning Funding2023-03-29029 March 2023 Decommissioning Funding NLS2023019, Property Insurance Coverage2023-03-23023 March 2023 Property Insurance Coverage NLS2023010, Inservice Inspection OAR-1 Owner'S Activity Report for Cooper Nuclear Station2023-02-0909 February 2023 Inservice Inspection OAR-1 Owner'S Activity Report for Cooper Nuclear Station NLS2023005, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20222023-01-19019 January 2023 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2022 NLS2022054, Preparation and Scheduling of Operator Licensing Examinations2023-01-0505 January 2023 Preparation and Scheduling of Operator Licensing Examinations NLS2022055, Emergency Plan, Revision 812023-01-0404 January 2023 Emergency Plan, Revision 81 NLS2022053, CNS-2022-11 Post Exam Submittal2022-11-22022 November 2022 CNS-2022-11 Post Exam Submittal NLS2022050, Notification of Revision to Cooper Nuclear Station Emergency Response Data System Data Point Library2022-11-0909 November 2022 Notification of Revision to Cooper Nuclear Station Emergency Response Data System Data Point Library NLS2022048, Management Change and Correspondence Update2022-11-0101 November 2022 Management Change and Correspondence Update NLS2022047, Core Operating Limits Report, Cycle 33, Revision 02022-10-14014 October 2022 Core Operating Limits Report, Cycle 33, Revision 0 NLS2022042, 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2) Summary Report2022-10-0707 October 2022 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2) Summary Report NLS2022037, Emergency Plan, Revision 80, Summary of 50.54(q) Analyses2022-08-18018 August 2022 Emergency Plan, Revision 80, Summary of 50.54(q) Analyses NLS2022035, Evacuation Time Estimate Report for Cooper Nuclear Station2022-08-16016 August 2022 Evacuation Time Estimate Report for Cooper Nuclear Station NLS2022031, Licensee Guarantees of Payment of Deferred Premiums2022-07-19019 July 2022 Licensee Guarantees of Payment of Deferred Premiums NLS2022005, Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2022-06-16016 June 2022 Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements NLS2022025, Nebraska Public Power District Letter (NLS2022010) to U.S. Nuclear Regulatory Commission Dated April 5, 2022, Annual Report of Individual Exposure Monitoring2022-06-0606 June 2022 Nebraska Public Power District Letter (NLS2022010) to U.S. Nuclear Regulatory Commission Dated April 5, 2022, Annual Report of Individual Exposure Monitoring NLS2022016, Annual Radiological Environmental Report2022-05-10010 May 2022 Annual Radiological Environmental Report NLS2022020, Nebraska Public Power District, Cooper Nuclear Station, 2021 Financial Report2022-05-0202 May 2022 Nebraska Public Power District, Cooper Nuclear Station, 2021 Financial Report NLS2022014, Annual Radioactive Effluent Release Report2022-04-27027 April 2022 Annual Radioactive Effluent Release Report NLS2022010, Annual Report of Individual Exposure Monitoring2022-04-0505 April 2022 Annual Report of Individual Exposure Monitoring NLS2022009, Property Insurance Coverage2022-03-23023 March 2022 Property Insurance Coverage NLS2022011, Preparation and Scheduling of Operator Licensing Examinations2022-03-18018 March 2022 Preparation and Scheduling of Operator Licensing Examinations NLS2022004, Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Relief Request RR5-01, Revision 12022-02-0707 February 2022 Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Relief Request RR5-01, Revision 1 NLS2022003, Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 20212022-01-20020 January 2022 Annual Report of Changes and Errors in Emergency Core Cooling System Evaluation Models for 2021 NLS2021067, ISFSI - Independent Spent Fuel Storage Installation Decommissioning Funding Plan2021-12-16016 December 2021 ISFSI - Independent Spent Fuel Storage Installation Decommissioning Funding Plan NLS2021069, Withdrawal of Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2021-12-15015 December 2021 Withdrawal of Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements NLS2021066, Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Alternative Request RI5-02, Revision 32021-12-10010 December 2021 Response to Nuclear Regulatory Commission'S Request for Additional Information Regarding Alternative Request RI5-02, Revision 3 NLS2021065, Clarification of Response to Nuclear Regulatory Commission'S Request for Additional Information for Alternative Request RS-012021-12-0606 December 2021 Clarification of Response to Nuclear Regulatory Commission'S Request for Additional Information for Alternative Request RS-01 NLS2021056, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2021-11-16016 November 2021 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements 2024-01-25
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N Nebraska Public Power District"Always there when you need us" 10 CFR 50.55a NLS2009006 February 16, 2009 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555-0001
Subject:
10 CFR 50.55a Request Number RI-2 1, Revision 0, and Request Number RI-22, Revision 0 Cooper Nuclear Station, Docket No. 50-298, DPR-46
Dear Sir or Madam:
The purpose of this letter is to request that the Nuclear Regulatory Commission (NRC) grant the Nebraska Public Power District (NPPD) relief from certain inservice inspection (ISI) code requirements for Cooper Nuclear Station (CNS) pursuant to 10 CFR 50.55a.10 CFR 50.55a Request Number RI-21, Revision 0, and Request Number RI-22, Revision 0, are applicable to the fourth ten-year ISI interval, which began March 1, 2006. NPPD requests NRC approval of the attached requests by February 28, 2010, which represents a standard twelve-month review period following submittal.
Approval of these requests is not needed to support future work at CNS.RI-21 is contained in Attachment 1 to this letter. NPPD has determined that compliance with the code requirements of achieving essentially 100% coverage of the welds listed in this attachment is impractical for CNS. Therefore, relief is required due to not achieving essentially 100% coverage.
CNS performed the examinations using the alternative examination volume defined in Code Case N-613-1, Figure 1, as approved in Regulatory Guide 1.147, Revision 15. The proposed alternative and basis for use is provided in Attachment 1 to this letter.RI-22 is contained in Attachment 2 to this letter. Similar to RI-21, NPPD has determined that compliance with the code requirements of achieving essentially 100% coverage of welds listed in this attachment is impractical for CNS. The proposed alternative and basis for use is provided in Attachment 2 to this letter.The examinations associated with both requests were performed in accordance with Appendix VIII of American Society of Mechanical EngineersSection XI using qualified personnel, procedures and equipment with the applicable limitations Set forth in 10 CFR 50.55a.COOPER NUCLEAR STATION 4 )q0 7 P.O, Box 98 / Brownville, NE 68321-0098 Telephone:
(402) 825-3817 / Fax: (402) 825-5211 www 'nppd.com NLS2009006 Page 2 of 2 Should you have any questions concerning this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.Brian J. O'Grady Site Vice President/dm Attachments cc: Regional Administrator w/attachments USNRC -Region IV Cooper Project Manager w/attachments USNRC -NRR Project Directorate IV-1 Senior Resident Inspector w/attachments USNRC -CNS NPG Distribution w/attachments CNS Records w/attachments NLS2009006 Attachment 1 Page 1 of 3 10 CFR 50.55a Request.Number RI-21, Revision 0 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality--
ASME Code Components Affected Code Class: 1
References:
IWB-2500, Table IWB-2500-1 Examination Category:
B-D -Full Penetration Welded Nozzles in Vessels Item Number: B3.90
Description:
Reactor Pressure Vessel Nozzle-to-Vessel Welds Component Numbers: NVE-BD-N1A, NVE-BD-N2E, NVE-BD-N2H, NVE-BD-N2K, NVE-BD-N3A, NVE-BD-N5A Applicable Code Edition and Addenda American Society of Mechanical Engineers (ASME) Code Section XI, 2001 Edition, 2003 Addenda.Applicable Code Requirement Table IWB-2500-1, Examination Category B-D, Item B3.90, requires 100% volumetric examination of the reactor vessel nozzle-to-vessel welds as defined by Figure IWB-2500-7(a). However, Cooper Nuclear Station (CNS) performed the examinations using the alternative examination volume defined in Code Case N-613-1, Figure 1, as approved in Regulatory Guide 1.147, Revision 15.Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), Nebraska Public Power District has determined that compliance with the code requirements of achieving essentially 100% coverage of the welds listed in Table RI-21-1 is impractical for CNS. The CNS construction permit was issued before the effective date of implementation for ASME Section XI, thus the plant was not designed to meet the requirements of inservice inspection.
The configuration of the nozzles, the design of the vessel insulation support rings and the nozzle access hatches, and interferences from thermocouple pads, instrument lines, etc., prevent 100 % examination of the required weld volumes.Burden Caused by Compliance A major modification to the reactor vessel nozzles and access hatches would be required in order to improve overall examination coverage.
Therefore, obtaining essentially 100%coverage is not feasible or practical.
NLS2009006 Attachment 1 Page 2 of 3 10 CFR 50.55a Request Number RI-21, Revision 0 Proposed Alternative and Basis for Use In lieu of performing the code-required examinations, CNS proposes to examine the accessible portions of reactor vessel nozzle-to-vessel welds to the extent practical.
The examinations were performed in accordance with Appendix VIII of ASME Section XI using qualified personnel, procedures and equipment with the applicable limitations set forth in 10 CFR 50.55a. The extent of the nozzle restrictions and the total volume accessible for examination, based on the examinations performed in the fourth interval are compared to examinations performed in the previous third interval.
In all cases, the coverage achieved in the fourth interval exceeded the coverage achieved in the previous interval.Duration of Proposed Alternative Relief is requested for the fourth ten-year interval of the Inservice Inspection Program for CNS.Precedents
- 1. Relief Request RI-21, Revision 2, was approved by the Nuclear Regulatory Commission on February 24, 2006, (TAC No. MC8512) for the third ten-year interval of the Inservice Inspection Program.Relief Request Table RI-21-1 Nozzle Nozzle Access Restrictions
% Examined % Examined Number Description 3 rd Interval 4 th Interval N1A Recirculation Nozzle configuration, and 32% 46%Inlet insulation support frame N2E, H Recirculation Nozzle configuration, and 40% 55%& K Outlet insulation support frame N3A Main Steam Nozzle configuration 35 % 49%N5A Core Spray Nozzle configuration, 31% 51%insulation support frame, and thermocouple pads NLS2009006 Attachment 1 Page 3 of 3 10 CFR 50.55a Request Number RI-21, Revision 0 The figure below shows the examination volume limitations to the applicable examination zones as required per ASME Section XI, Figure IWB-2500-7(a):
Shell!FIGURE RI-21-1 (Typical)8?RL Ext Pau L06, 1 S Nozzle NLS2009006 Attachment 2 Page 1 of 3 10 CFR 50.55a Request Number RI-22, Revision 0 Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iii)
--Inservice Inspection Impracticality--
ASME Code Components Affected Code Class: 1
References:
IWB-2500, Table IWB-2500-1 Examination Category:
B-F -Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles (R-A)Item Number: B5.10
Description:
Nozzle-to-Safe End Butt Welds Component Numbers: CSA-BF-lx, RRH-BF-1, RRK-BF-1, RRE-BF-1 Applicable Code Edition and Addenda American Society of Mechanical Engineers (ASME) Code Section XI, 2001 Edition, 2003 Addenda.Applicable Code Requirement Table IWB-2500-1, Examination Category B-F, Item B5. 10, requires 100 % volumetric examination of the pressure retaining dissimilar metal welds in vessel nozzles as defined by Figure IWB-2500-8.
Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), Nebraska Public Power District has determined that compliance with the code requirements of achieving essentially 100% coverage of welds listed in Table RI-22-1 is impractical for Cooper Nuclear Station (CNS).CNS replaced the Class 1 stainless steel piping in the mid- 1980's. The best techniques available to mitigate intergranular stress corrosion cracking (IGSCC) were used: IGSCC resistant material, corrosion resistant cladding on the internal diameter of the nozzle buttering, and Induction Heat Stress Improvement (IHSI). These activities provided welds that are Generic Letter 88-01 IGSCC Category "A." The resultant welds were examined using the standard industry techniques for IGSCC at that time.Typical volumetric examination coverage was previously reported to be greater than 90 %. The radial shrinkage caused by the IHSI in the heat affected zone areas during the construction of the welds prevents full contact of the ultrasonic testing (UT) probes.
NLS2009006 Attachment 2 Page 2 of 3 10 CFR 50.55a Request Number RI-22, Revision 0 Burden Caused by Compliance Removal of the nozzle base metal by grinding or machining would be required to obtain a surface conducive for examination.
Therefore, obtaining essentially 100% coverage is not feasible or practical.
Proposed Alternative and Basis for Use In lieu of performing the code-required examinations, CNS proposes to examine the accessible portions of reactor vessel nozzle-to-safe-end welds to the extent practical.
The examinations were performed in accordance with Appendix VIII of ASME Section XI using qualified personnel, procedures and equipment with the applicable limitations set forth in 10 CFR 50.55a. The current Performance Demonstration Initiative (PDI)techniques that implement Appendix VIII of ASME Section XI are more restrictive on the requirements for weld profiles.
The current examinations are considered more reliable than previously performed volumetric examinations.
The weld profile shown in Figure RI-22-1, indicates that the shrinkage in the heat affected zone on the nozzle side caused a greater than 1/32" gap between the UT search unit and examination surface. Both axial UT scans obtained 100% coverage necessary to detect circumferential flaws. However, the circumferential scans necessary to detect axial flaws could not be fully obtained.
The circumferential scan on the safe-end was obtained but the circumferential scan on the nozzle side could not be obtained thus resulting in the combined volumetric coverage estimates provided in Table RI-22-1.The examination coverage achieved for the required examination volume of ASME Section XI Figure IWB-2500-8 and the CNS Risk-Informed Program was obtained as follows: 0 50% Code volume based on achieving 100% coverage of the two required axial scans for the detection of circumferentially oriented flaws* 25 % Code volume based on achieving 100 % coverage of one the two required circumferential scans for the detection of axially oriented flaws The coverage calculation is based on obtaining full coverage on three of the four scans:* Axial scan coverage (50%) + Circumferential scan coverage (50% /2=25 %)75%
NLS2009006 Attachment 2 Page 3 of 3 10 CFR 50.55a Request Number RI-22, Revision 0 Duration of Proposed Alternative Relief is requested for the fourth ten-year interval of the Inservice Inspection Program for CNS.Relief Request Table RI-22-1 Weld System Access Restrictions
%Number Examined CS-BF-lx Core Spray Weld Contour 75 RRE-BF-1 Recirculation Weld Contour 75 Outlet RRH-BF-1 Recirculation Weld Contour 75 Outlet RRK-BF-1 Recirculation Weld Contour 75 Outlet The figure below shows the examination volume limitations to the applicable examination zones as required per ASME Section XI, Figure IWB-2500-8:
FIGURE RI-22-1 (Typical)Radial Shrink Area Limitation Safe End 316 L Stainless Stainless Steel Clad ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4 Correspondence Number: NLS2009006 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 N/A N/A 1- 4 4. 4 4- 4*1 4*1 4 I t I PROCEDURE 0.42 REVISION 23 PAGE 18 OF 25 1