ML021410313
| ML021410313 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/16/2002 |
| From: | Fader G Wolf Creek |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BL-02-001, ET 02-0021 | |
| Download: ML021410313 (5) | |
Text
W*LF CREEK
'NUCLEAR OPERATING CORPORATION Gary B. Fader Vice President Technical Services MAY 1 6 2002 ET 02-0021 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
Reference:
Letter ET 02-0018, dated April 3, 2002, from Richard A. Muench, WCNOC, to USNRC
Subject:
Docket No. 50-482: 60-Day Response for NRC Bulletin 2002-01, "Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity" Gentlemen:
This letter provides the Wolf Creek Nuclear Operating Corporation (WCNOC) response to the 60-day requirement of U.S. Nuclear Regulatory Commission (NRC)Bulletin 2002-01, "Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity" dated March 18, 2002. Item 3.A of the bulletin requires information relative to reasonable assurance of compliance with applicable regulatory requirements related to the boric acid corrosion program for the remainder of the reactor coolant pressure boundary be submitted within 60 days.
Also included in this letter is information satisfying a commitment made in the WCNOC response to NRC Bulletin 2002-01 (Reference) relative to future inspections of the reactor pressure vessel head and penetration nozzles.
No commitments are identified in this submittal.
If you should have any questions regarding this submittal, please contact me at (620) 364-4034, or Mr. Tony Harris at (620) 364-4038.
Very truly yours, Gary B. Fader GBF/rlr Attachment P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET
ET 02-0021 Page 2 of 2 cc:
J. N. Donohew (NRC), w/a D. N. Graves (NRC), w/a E. W. Merschoff (NRC), w/a Document Control Desk. w/a Senior Resident Inspector (NRC), w/a
STATE OF KANSAS
)
) SS COUNTY OF COFFEY )
Gary B. Fader, of lawful age, being first duly sworn upon oath says that he is Vice President Technical Services of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
B y_
Bary B. Fader Vice President Technical Services SUBSCRIBED and sworn to before me this a day of feYl
, 2002.
CIND N Notary Public)
IAnOF KAMd$IM Expiration Date 1-U
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/
Attachment to ET 02-0021 Page 1 of 2 60-Day Response to NRC Bulletin 2002-01 Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity Below is the Wolf Creek Nuclear Operating Corporation (WCNOC) response to the 60-day requirement of U.S. Nuclear Regulatory Commission (NRC)Bulletin 2002-01, "Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity," dated March 18, 2002. The bulletin's "Required Information" is shown in bold. Also included after the response to item 3.A. below is information satisfying a commitment made in the WCNOC response to NRC Bulletin 2002-01 (Reference 1) relative to evaluating enhancements to current inspection programs and practices for future inspections of the reactor pressure vessel head and penetration nozzles.
Required Information
- 3.
Within 60 days of the date of this bulletin, all PWR addressees are required to submit to the NRC the following information related to the remainder of the reactor coolant pressure boundary:
A.
the basis for concluding that your boric acid inspection program is providing reasonable assurance of compliance with the applicable regulatory requirements discussed in Generic Letter 88-05 and this bulletin.
If a documented basis does not exist, provide your plans, if any, for a review of your programs.
Response
WCNOC has reasonable assurance that regulatory requirements pertaining to reactor coolant pressure boundary integrity are being met and will continue to be met in the future. Compliance with the applicable regulatory requirements discussed in Generic Letter 88-05 and NRC Bulletin 2002-01 is described in the WCNOC response to NRC Bulletin 2002-01 (Reference 1).
WCNOC's policy is to minimize boric acid corrosion by applying integrated programs that provide for: 1) early detection of boric acid leaks; 2) inspection of areas surrounding identified boric acid leakage; 3) removal of boric acid from components; 4) evaluation of areas where leakage has occurred; and 5) action to mitigate the leak, perform repairs, and avoid future damage. The following information on WCNOC's boric acid corrosion inspection (BACINS) program provides the basis that reasonable assurance exists for current and future conformance with regulatory requirements.
The BACINS program applies to systems that contain boric acid. This includes systems from which leakage could potentially affect the reactor coolant pressure boundary.
Boric acid leakage may be identified during BACINS program inspections, ASME Section XI system leakage inspections, and during scheduled containment entries which include area housekeeping inspections.
Other activities that could identify boric acid leakage include the reactor coolant system (RCS) leakage surveillance test (to quantify identified and unidentified RCS leakage per Technical Specifications), monitoring containment radiation levels, and monitoring containment sumps levels.
Attachment to ET 02-0021 Page 2 of 2 Both the BACINS program procedure and the ASME Section Xl system leakage test procedure have similar inspection requirements relative to identifying boric acid leaks. Each procedure has specific lists of components and areas to inspect.
Both procedures also require the inspection personnel to be Level II certified, as a minimum, for the visual examination (VT-2) method.
The BACINS program procedure is performed at the beginning of each refueling outage as RCS temperature and pressure are decreasing, and may be performed during other outages, at the discretion of station management. This inspection is typically completed early in an outage to preserve evidence of boric acid leakage prior to maintenance activities.
The ASME Section XI system leakage test is performed near the end of a refueling outage, or any other outage that affects the reactor coolant pressure boundary.
In accordance with ASME Section XI requirements, this test is performed at normal operating pressure.
If evidence of boric acid leakage is identified by any of the activities described above, or at any time during general work activities, procedural controls require initiation of documentation in accordance with WCNOC work control and corrective action programs. Administrative controls for identified boric acid leakage require locating the source of the leak, identifying other impacted components, cleaning boric acid from components, and determining if boric acid corrosion has occurred.
Engineering evaluations are required for any components to be returned to service with identified active leakage, and any components identified with corrosion caused by boric acid leakage.
The BACINS program engineer reviews relevant industry operating experience for possible incorporation into applicable plant programs. Boric acid corrosion operating experience is also an integral part of both initial training and periodic continuing training for the certified examiners described above.
Based on the above, WCNOC has reasonable assurance that regulatory requirements discussed in Generic Letter 88-05 and NRC Bulletin 2002-01 pertaining to reactor coolant pressure boundary integrity are being met and will continue to be met in the future.
Schedule and Plans for Future Inspections of the Reactor Vessel Head and Penetration Nozzles:
As described the WCNOC response to NRC Bulletin 2002-01 (Reference 1), a remote visual inspection of the reactor vessel head has been completed.
Determination of inspection frequency and detailed inspection requirements for future inspections are pending the final results of ongoing industry initiatives.
Reference
- 1. Letter ET 02-0018 from Rick Muench, WCNOC, to USNRC, "Response to NRC Bulletin 2002-01, Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity," dated April 3, 2002.