NLS2013100, Letter Regarding Implementation of License Renewal Commitments, (NLS2013090)
| ML13336A143 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/26/2013 |
| From: | Limpias O Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2013100 | |
| Download: ML13336A143 (3) | |
Text
N Nebraska Public Power District Always there when you need us NLS2013 100 November 26, 2013 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
New License Renewal Commitment Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
Letter from David W. Van Der Kamp, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated October 3, 2013, "Implementation of License Renewal Commitments" (NLS2013090)
Dear Sir or Madam:
The purpose of this letter is to make an additional commitment related to the license renewal One-time Inspection Aging Management Program.
In the referenced letter, the Nebraska Public Power District (NPPD) notified the Nuclear Regulatory Commission (NRC) of the completion of License Renewal commitment NLS2008071-20 Revision 3:
Implement the One-time Inspection Program. [LRA Section B. 1.29, except that:
a) "surface condition" (from NUREG-1801 Revision 2 Section XI.M32 "Examples of Parameters Monitored or Inspected and Aging Effect for Specific Structure or Component" table) is included as a parameter monitored for loss of material and cracking, b) the CASS main steam line and reactor recirculation flow elements do not require inspection to confirm that reduction of fracture toughness is not occurring, and c) a representative sample size will be 20% of the population (defined as components having the same material, environment, and aging effect combination), or a maximum of 25 components.]
In that commitment, Exception b) reflected a commitment change which removed the inspection of the cast austenitic stainless steel (CASS) material, of the reactor recirculation and main steamline restricting orifices from the program. That commitment change relied on a site-specific analysis performed by General Electric-Hitachi (GEH) that demonstrated that these components would have adequate fracture toughness during the period of extended operation (PEO). During the recent IP 71003 Phase 2 inspection conducted at Cooper Nuclear Station (CNS), it was noted that the GEH analysis used the same methodology for determining ferrite content that was used in BWRVIP-234, "Thermal Aging and Neutron Embrittlement Evaluation of Cast Austenitic Stainless Steel For BWR Internals." Inasmuch as BWRVIP-234 is still under COOPER NUCLEAR STATIONfll P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax. (402) 825-5211 www.nppd.com
NLS2013 100 Page 2 of 2 review by the NRC, the inspectors did not believe it was appropriate to close the license renewal commitment until a Safety Evaluation had been issued approving BWRVIP-234 for use. In lieu of keeping the One-time Inspection Program open, NPPD proposed to make a new commitment that was specific to the one-time inspection of the CASS reactor recirculation and main steamline flow restrictors. This approach was found acceptable by NRC Region 4 management.
Accordingly, NPPD makes the following new License Renewal commitment (see Attachment):
NPPD will confirm that the reactor recirculation and main steamline flow restrictor CASS materials are either: a) not greater than 25% ferrite, or b) will perform a flaw tolerance evaluation, or c) will perform a qualified visual or volumetric examination.
This will be completed within three years after the period of extended operation.
This completion date is consistent with the other CNS post-PEO license renewal commitments.
NPPD intends to include this commitment in the Updated Safety Analysis Report similar to the other license renewal commitments.
Should you have any questions regarding this submittal, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.
Since IL Limpias Vice President -
uclear and Chief Nuclear Officer OAL/wv
Attachment:
List of Regulatory Commitments cc:
Regional Administrator w/ Attachment USNRC - Region IV Cooper Project Manager w/ Attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ Attachment USNRC - CNS NPG Distribution w/ Attachment CNS Records w/ Attachment
NLS2013 100 Attachment Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Nebraska Public Power District in this document. Any other actions discussed in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE (Check one)
SCHEDULED COMMITMENT/COMMITMENT NO.
ONE-TIME CONTINUING COMPLETION ACTION COMPLIANCE DATE NPPD will confirm that the reactor X
1/18/2017 recirculation and main steamline flow restrictor CASS materials are either: a) not greater than 25% ferrite, or b) will perform a flaw tolerance evaluation, or c) will perform a qualified visual or volumetric examination. This will be completed within three years after the period of extended operation. (NLS2013100-01) 4 4
4 4