ET 06-0044, Operating Corporation'S Revised Commitment Regarding 10 CFR 50.55a Request I3R-05

Operating Corporation'S Revised Commitment Regarding 10 CFR 50.55a Request I3R-05

ML062850505
Person / Time
Site:	Wolf Creek
Issue date:	10/02/2006
From:	Garrett T Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 06-0044, I3R-05
Download: ML062850505 (7)

Text

W*1LF CREEK 'NUCLEAR OPERATING CORPORATION Terry J. Garrett Vice President Engineering October 2, 2006 ET 06-0044 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 06-0042, dated September 27, 2006, from T. J. Garrett, WCNOC, to USNRC

2) Letter ET 06-0031, dated August 4, 2006, from T. J. Garrett, WCNOC, to USNRC

3) Letter ET 06-0021, dated May 19, 2006, from T. J. Garrett, WCNOC, to USNRC

Subject:

Docket 50-482: Wolf Creek Nuclear Operating Corporation's Revised Commitment Regarding 10 CFR 50.55a Request 13R-05 Gentlemen:

Reference 3 provided Wolf Creek Nuclear Operating Corporation (WCNOC) 10 CFR 50.55a Request 13R-05, which requested alternatives to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV),Code,Section XI for the installation and examination of full structural weld overlays for repairing/mitigating Pressurizer nozzle-to-safe end dissimilar metal (DM) and safe end-to-piping stainless steel (SS) butt welds.

Reference 2 provided WCNOC's responses to a July 6, 2006 Nuclear Regulatory Commission (NRC) request for additional information (RAI) regarding the WCNOC 10 CFR 50.55a Request 13R-05 and provided Revision 1 to 13R-05 to address two WCNOC responses to the RAI.

Reference 1 provided WCNOC's responses to RAIs provided electronically on September 20, 2006.

/ Phone: (620) 364-8831 P.O. Box 411 / Burlington, KS 66839 An Equal Opportunity Employer M/F/HCNET

ET 06-0044 Page 2 of 2 During subsequent discussions between the NRC and WCNOC staff on September 28, 2006 and October 2, 2006, it was determined that additional information was needed related to the commitments made in Reference 1. It was also noted in these discussions that minor clarifications were needed in Table 5, Weld Overlay Examination Requirements, which was provided by Reference 2. Therefore, WCNOC has revised the commitment page to include information relevant to subsequent inservice examinations and to include two footnotes that reiterate information found in the Performance Demonstration Initiative qualified ultrasonic examination procedures discussed in Request 13R-05, Revision 1, in Reference 2. WCNOC has also made the requested changes to Table 5 originally submitted by Reference 2. to this letter provides WCNOC's revised list of commitments regarding 10 CFR 50.55a Request 13R-05. Enclosure 1 to this letter provides changes to Table 5. If you have any questions, please contact me at (620) 364-4084 or Mr. Kevin Moles at (620) 364-4126.

Sincerely Terry J. Garrett TJG/rlt : Revised List of Commitments : Revised Table 5 from ET 06-0031 cc: J. N. Donohew (NRC), w/a, w/e G. E. Werner (NRC), w/a. w/e B. S. Mallett (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

Attachment 1 to ET 06-0044 Page 1 of 1 REVISED LIST OF COMMITMENTS The following table identifies revised commitments by Wolf Creek Nuclear Operating Corporation (WCNOC) provided in letter ET 06-0042. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Kevin Moles at (620) 364-4126.

COMMITMENT Due DatelEvent WCNOC will notify the NRC Project Manager for Wolf Creek When the final UT Generating Station (WCGS) when the ultrasonic (UT) examination of the examination of the final full structural weld overlay is complete. weld overlays during WCNOC's Fall 2006 Refueling Outage is completed.

WCNOC will provide the results of the UT examinations of the Within 14 days of full structural weld overlays of the WCGS Pressurizer safety, completion of the relief, spray and surge line nozzle welds to the NRC. final UT examination of the weld overlays The results will include: during WCNOC's Fall 2006 Refueling A listing of indications detected1; Outage.

• The disposition of all indications using the standards of ASME Section XI, Table IWB-3514-2 and/or Table IWB-3514-3; and, if possible,

• The type and nature of the indications2 Also included in the results will be a discussion of any repairs to the overlay material and/or base metal and the reason for the repair.

Subsequent inservice examination of full structural repair weld overlays on the Pressurizer nozzle welds will be in accordance with the 2004 Edition with 2005 Addenda of ASME Section XI, Appendix Q, Q-4300 as prescribed in WCNOC Request 13R-05, Rev. 1, Table 5, page 27 of 28, attached to WCNOC letter ET 06-0044 dated October 2, 2006. Subsequent inservice examinations of preemptive full structural weld overlays on the Pressurizer nozzle welds will be as prescribed in WCNOC Request 13R-05, Rev. 1, Table 5, page 28 of 28, attached to WCNOC letter ET 06-0044 dated October 2, 2006.

1 The recording criteria of the ultrasonic examination procedure to be used for the examination of the WCGS Pressurizer weld overlays (PDI-UT-8, Revision F) requires that all indications, regardless of amplitude, be investigated to the extent necessary to provide accurate characterization, identity, and location. Additionally, the procedure requires that all indications, regardless of amplitude, that cannot be clearly attributed to the geometry of the overlay configuration be considered flaw indications.

2 Ultrasonic examination procedure PDI-UT-8, Revision F, requires that all suspected flaw indications are to be plotted on a cross sectional drawing of the weld and that the plots should accurately identify the specific origin of the reflector.

Enclosure 1 to ET 06-0044 Changes to Table 5: Weld Overly Examination Requirements (Pages 26-28 of Request 13R-05, Rev. 1, submitted in letter ET 06-0031)

10 CFR 50.55a Request Number 13R-05, Revision I I Table 5: Weld Overlay Examination Requirements IN-PROCESS EXAMINATIONS Examination Description* Method Technique Reference Acceptance Standards Safe end, welds, nozzle, and pipe pre-overlay Surface Liquid Penetrant N-504-3 and Q-2000 N-504-3, Paragraph (c), Q-surface preparation. 2000 (b)

Corrective layers of weld metal, if required, Surface Liquid Penetrant N-504-3 and Q-2000 N-504-3, Paragraph (d), Q-not associated with the structural weld 2000(c) overlay.

Thickness measurements for verifying final Volumetric UT-0 0L N-504-3 and Q-3000 Per weld overlay design deposited weld reinforcement, I I I requirements and Q-3000 COMPLETED WELD OVERLAY EXAMINATION and PRESERVICE EXAMINATION REQUIREMENTS Examination Description* Method Technique Reference Acceptance Standards Examination of the completed weld overlay Surface Liquid Penetrant N-504-3, N-638-1, and Q-4 100 (b) and examination of a band around the entire Q-4100 circumference of the nozzle and pipe at least 1.5 times the nozzle end thickness outward from the toe of the weld overlay on the nozzle side and at least 0.50 inches outward from the toe of the weld overlay on the pipe side. For the portion of the weld overlay installed per Code Case N-638-1 and the band area on the nozzle side, this examination will occur at least 48 hrs. after the completed weld overlay has returned to ambient temperature.

Completed weld overlay for complete Volumetric UT-0%L; N-504-3, N-638-1, Q- Thickness per weld bonding and minimum thickness and for UT angle beam per 4100, and Appendix overlay design detection of welding flaws. Examination for PDI-qualified VIII requirements in Q-3000 bonding and welding flaws in the portion of procedures and bonding and welding the weld overlay installed per Case N-638-1 flaws per Q-4100(c) will occur at least 48 hrs. after the completed weld overlay has returned to ambient temperature.

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10 CFR 50.55a Request Number 13R-05, Revision I Table 5: Weld Overlay Examination Requirements Completed weld overlay and the outer 25 Volumetric UT angle beam per N-504-3, N-638-1, Q- N-504-3, Paragraph (i) and percent of the original DM weld thickness at PDI-qualified 4200, and Appendix Q-4200 least 0.5-inches beyond the toes of the procedure VIII original DM weld and butter and at least 0.5 inches beyond any as-found flaw. For N-638-1 welding, this examination will occur at least 48 hrs. after the completed weld overlay has returned to ambient temperature.

Completed weld overlay and the outer 25 Volumetric UT angle beam per N-504-3, Q-4200, and N-504-3, Paragraph (i) and percent of the original SS pipe weld PDI-qualified Appendix VIII Q-4200 thickness at least 0.5-inches beyond the toes procedure of the original SS weld and at least 0.5 inches beyond any as-found flaw.

INSERVICE EXAMINATION REQUIREMENTS Examination Description* Method Technique Reference Acceptance Standards Full Structural Repair WOL: Weld overlay Volumetric UT angle beam per ASME Section XI Q-4300 and outer 25 percent of the original DM weld PDI procedure Appendix VIII and Q-thickness at least 0.5-inches beyond the toes 4300 of the original DM weld and butter, and at least 0.5 inches beyond any as-found flaw, will be examined within the next two refueling outages. Re-examination will be on a sampling basis in accordance with Q-4300(b) through (f) and Q-4310. These examinations will be added to the IS1 Program Plan in accordance with IWB-2412(b)(1).

Full Structural Repair WOL: Weld overlay Volumetric UT angle beam per ASME Section XI Q-4300 and outer 25 percent of the original SS pipe PDI procedure Appendix VIII and Q-weld thickness at least 0.5-inches beyond the 4300 toes of the original SS weld, and at least 0.5 inches beyond any as-found flaw, will be examined within the next two refueling outages. Re-examination will be on a 27 of 28 I

I, 10 CFR 50.55a Request Number 13R-05, Revision I I

Table 5: Weld Overlay Examination Requirements sampling basis in accordance with Q-4300(b) through (f) and Q-43 10. These examinations will be added to the IST Program Plan in accordance with IWB-2412(b)(1).

Preemptive Full Structural WOL: If greater Volumetric UT angle beam per ASME Section XI Q-4300(b) and (c) than or equal to 90% coverage of the original PDI procedure Appendix VIII and Q-DM weld is achieved with PDI qualified 4300 para. (b) through procedures and no service related indications (f) and Q-4310 are identified, the weld overlay and outer 25 percent of the original DM weld thickness at least 0.5-inches beyond the toes of the original DM weld and butter will be examined on a sampling basis in accordance with Q-4300(b) through (f) and Q-4310.

These examinations and frequency of performance will be added to the ISI Program Plan in accordance with IWB-2412(b)(1).

Preemptive Full Structural WOL: If greater Volumetric UT angle beam per ASME Section XI Q-4300(b) and (c) than or equal to 90% coverage of the original PDI procedure Appendix VIII and Q-SS weld is achieved with PDI qualified 4300 para. (b) through procedures and no service related indications (f) and Q-4310 are identified, the weld overlay and outer 25 percent of the original SS weld thickness at least 0.5-inches beyond the toes of the original SS weld will be examined on a sampling basis in accordance with Q-4300(b) through (0 and Q-4310. These examinations and frequency of performance will be added to the ISI Program Plan in accordance with IWB-2412(b)(1).

• This is a general examination description of the examinations to be performed; it does not identify all requirements for performing the examinations. As noted on page 6 of 28 of 10 CFR 50.55a Request 13R-05, Revision 1, submitted by letter ET 06-003 1, the examination requirements comply with non-mandatory Appendix Q except as noted.

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