ET 08-0010, Withdrawal of License Amendment Request for a Permanent Alternate Repair Criteria in Technical Specification (TS) 5.5.9, Steam Generator (SG) Program.

Withdrawal of License Amendment Request for a Permanent Alternate Repair Criteria in Technical Specification (TS) 5.5.9, Steam Generator (SG) Program.

ML080580201
Person / Time
Site:	Wolf Creek
Issue date:	02/14/2008
From:	Garrett T Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 08-0010, TAC MC6757, TAC MD2467
Download: ML080580201 (2)

Text

WLF CREEK

'NUCLEAR OPERATING CORPORATION Terry J. Garrett February 14, 2008 Vice President, Engineering ET 08-0010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter dated April 28, 2005, from J. N. Donohew, USNRC, to R. A. Muench, WCNOC, "Wolf Creek Generating Station -

Issuance of Exigent Amendment RE: Steam Generator (SG)

Tube Surveillance Program (TAC NO. MC6757)"

2) Letter dated October 10, 2006, from J. N. Donohew, USNRC, to R. A. Muench, WCNOC, "Wolf Creek Generating Station -

Issuance of Amendment RE: Steam Generator Tube Inspections Within the Tubesheet (TAC NO. MD 2467)

3) Letter ET 06-0004, dated February 21, 2006, from T. J. Garrett, WCNOC, to USNRC

4) Letter WO 07-0012, dated May 3, 2007, from S. E. Hedges, WCNOC, to USNRC

5) Letter ET 07-0043, dated September 27, 2007, from T. J. Garrett, WCNOC, to USNRC

6) Letter dated January 25, 2008, from J. H. Riley, NEI, to J. W.

Lubinski, USNRC

7) Letter ET 08-0009, dated February 8, 2008, from T. J. Garrett, WCNOC, to USNRC

Subject:

Docket No. 50-482: Withdrawal of License Amendment Request for a Permanent Alternate Repair Criteria in Technical Specification (TS) 5.5.9, "Steam Generator (SG) Program" Gentlemen:

References 1 and 2 approved one-cycle revisions to Technical Specification (TS) 5.5.9, "Steam Generator (SG) Program," to exclude from inspection and repair, portions of the tube below the top of the tubesheet in the Wolf Creek Generating Station (WCGS) steam generators.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET t 1 .6

ET 08-0010 Page 2 of 2 Reference 3 submitted a license amendment request proposing a permanent alternate repair criteria to TS 5.5.9 to limit the inspection depth in the SG tube expansion zone, known as H*/B*.

References 4 and 5 provided responses to Requests for Additional Information associated with the permanent revision to TS 5.5.9.

On December 20, 2007, NRC Division of Operating Reactor Licensing personnel contacted WCNOC executive management and indicated that the NRC would not be able to approve the proposed permanent revision to TS 5.5.9 to support. the Spring 2008 refueling outage (March 2008). The Staff indicated that they would entertain-a one-cycle amendment request but would entail changes from the currently approved one-cycle amendments. Reference 7 submitted a license amendment request for interim alternate repair criteria for the Spring 2008 refueling outage.

On February 7, 2008, a teleconference was held with representatives from the Nuclear Energy Institute (NEI), Wolf Creek Nuclear Operating Corporation (WCNOC), Exelon Generation Company, Southern Nuclear Operating Company, and the Nuclear Regulatory Commission, (NRC). During this teleconference, the NRC indicated that the denial process for the permanent amendment application (Reference 3) would result in competing resources for the review of the license amendment request for the interim alternate repair criteria. Based on this information, WCNOC is withdrawing the permanent license amendment request for the permanent alternate repair criteria and requests the NRC to provide the specific issues remaining to be resolved on the permanent amendment request. The H*/B* approach remains a valid approach for addressing degradation in the lower portion of the SG tube.

The industry has convened an expert panel reviewing key aspects of the H* analysis and providing input towards the resolution of the remaining technical issues for approval of a permanent alternate repair criteria (Reference 6). WCNOC supports the use of an expert panel and requests the NRC work with the industry and the expert panel in supportof a permanent.

license amendment for addressing degradation in the lower portion of the SG tube.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4084 or Mr. Richard D. Flannigan at (620) 364-4117.

Sincerely

1. J Garrett TJG/rlt cc: E. E. Collins (NRC)

J. N. Donohew (NRC)

V. G. Gaddy (NRC)

B. K. Singal (NRC)

Senior Resident Inspector (NRC)