ML071990100
| ML071990100 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/11/2007 |
| From: | Garrett T Wolf Creek |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ET 07-0028 | |
| Download: ML071990100 (8) | |
Text
CREEK NUCLEAR OPERATING CORPORATION Terry J. Garrett Vice President, Engineering July 11, 2007 ET 07-0028 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Reference:
Subject:
- 1) Letter ET 06-0038, dated September 27, 2006, from T.J. Garrett, WCNOC, to USNRC 2) Letter ET 07-0011, dated May 2, 2007, from T.J. Garrett, WCNOC, to USNRC 3) Telephone Conference Summary dated June 15, 2007, from V. Rodriguez, USNRC (ML071640024)
- 4) Telephone Conference Summary dated June 25, 2007, from V. Rodriguez, USNRC (ML071690318)
Docket No. 50-482: Followup Response to NRC Requests for Additional Information Related to Wolf Creek Generating Station License Renewal Application Gentlemen:
Reference 1 provided Wolf Creek Nuclear Operating Corporation's (WCNOC) License Renewal Application for the Wolf Creek Generating Station (WCGS). Reference 2 provided WCNOC responses to NRC requests for additional information (RAI) regarding the License Renewal Application.
References 3 and 4 documented telephone conference calls held on June 8, 2007 and June 14, 2007 to discuss and clarify the WCNOC responses.
Attachment I provides followup responses to the RAIs discussed on the conference calls.Attachment II provides a summary of the commitments made in this response.If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr.Kevin Moles at (620) 364-4126.Sincerp, Terry J. Garrett TJG/rlt P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET ET 07-0028 Page 2 of 3 Attachments I II WCNOC Followup Response to NRC Requests for Additional Information List of Commitments cc: J. N. Donohew (NRC), w/a V. G. Gaddy (NRC), w/a B. S. Mallett (NRC), w/a V. Rodriguez (NRC), w/a Senior Resident Inspector (NRC), w/a ET 07-0028 Page 3 of 3 STATE OF KANSAS COUNTY OF COFFEY))Terry J. Garrett, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering 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.Vice Engineering SUBSCRIBED and sworn to before me this 1 Itw'day of 3Ul(, 2007.z 6FICIA RHONDA L. TIEMEYER77 0AL: MY COMMISSION EXPIRES Notary Public January 11,2010 I Expiration Date Q/jTLqj) 1 ID Attachment I to ET 07-0028 Page 1 of 4 Attachment I Wolf Creek Nuclear Operating Corporation's (WCNOC) Followup Response to NRC Requests for Additional Information (RAI) Related to Wolf Creek Generating Station (WCGS) License Renewal Application (LRA)RAI 2.3.3.16-1 RAI 2.3.4.2-1 RAI 2.3.4.2-2 RAI 2.3.4.2-5 RAI 2.3.3.14-5 Attachment I to ET 07-0028 Page 2 of 4 Emergency Diesel Engine System RAI 2.3.3.16-1 FollowuD Discussion During a telephone conference call on June 8, 2007, the staff requested that the applicant justify why tank vents are not included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) as they functionally support the operation of the tank.RAI 2.3.3.16-1 Followup Response As a follow-up to RAI 2.3.3.16-1, the vent line for the Emergency Diesel Engine Jacket Water Expansion Tanks will be included within the scope of license renewal.The tank vents are vendor supplied components and do not have unique plant tag numbers. The tank vents will be added as a generic piping component.
LRA Table 2.3.3-16 will be amended to include "Leakage Boundary Spatial" (LBS) to the Intended Functions for the Component Type "Piping".LRA Table 3.3.2-16 will be amended to add the following two new lines: Component Type: Piping Intended Function:
LBS Material:
Carbon Steel Environment:
Wetted Gas (internal)
Aging Effect: Loss of Material AMP: Inspection of Internal Surfaces in Miscellaneous Piping &Ducting (B2.1.22)NUREG-1801 Vol 2 Item: VII.H2-21 Table I Item: 3.3.1.71 Note: Component Type: Intended Function: Material: Environment:
Aging Effect: AMP: NUREG-1801 Vol 2 Item: Table I Item: Note: A Piping LBS Carbon Steel Plant Indoor Air (external)
Loss of Material External Surfaces Monitoring Program (B2.1.20)VII.I-8 3.3.1.58 A Attachment I to ET 07-0028 Page 3 of 4 Main Steam System RAI 2.3.4.2-1 Followup Discussion During a telephone conference call on June 8, 2007, the staff indicated that the response to this RAI requires clarification.
The staff requested that the applicant address the potential effects of a degraded exhaust silencer on the intended function of the atmospheric relief valves. The staff also requested that the applicant identify that no age related degradation of the atmospheric relief valve silencers could affect their intended function.RAI 2.3.4.2-1 Followup Response The atmospheric relief valves exhaust silencers will be included in the scope of license renewal. The affected LRA sections will be amended: (a) LRA Table 2.3.4-2 will be updated to include the component type "Silencer" with intended function of "direct flow", (b) LRA Section 3.4.2.1.2 will be updated to add an environment of Atmosphere/Weather. (c) LRA Table 3.4.2-2 will be updated to add a carbon steel silencer in an atmosphere/weather environment (external) and wetted gas environment (internal).
Consistent with NUREG-1801, line VIII.H-8, Loss of Material on the external surfaces of the silencer will be managed with the "External Surface Monitoring" AMP (B2.1.20).
Also, consistent with NUREG-1801, line VIII.B1-7, Loss of Material on the internal surfaces of the silencer will be managed with the "Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components" AMP (B2.1.22).
RAI 2.3.4.2-2 Followup Discussion During a telephone conference call on June 8, 2007, the staff indicated that the response to this RAI requires clarification.
The staff requested that the applicant address the function of the steam trap as a valve body with a pressure boundary function and that the steam trap's configuration be described.
The staff requested that the applicant clarify if there is an analysis or calculation that justify the exclusion of the steam traps from the scope of license renewal.RAI 2.3.4.2-2 Followup Response The current WCGS license basis for Post-Fire Safe Shutdown (PFSSD) includes calculation XX-E-013 "Post-Fire Safe Shutdown Analysis." Calculation XX-E-013, which lists the components required for PFSSD, does not include any components in the turbine building on lines of 1" or less. The steam traps discussed in RAI 2.3.4.2-2 (ST0001, ST0002, ST0003, and ST0004) are located on lines of 1" or less. Therefore, these steam traps are not components required for PFSSD and are not within the scope of license renewal.
Attachment I to ET 07-0028 Page 4 of 4 RAI 2.3.4.2-5 Followup Discussion During a telephone conference call on June 8, 2007, the staff indicated that the response to this RAI requires clarification.
The staff requested that the applicant clarify if there is an analysis or calculation that justify the exclusion of the 1" diameter piping from the scope of license renewal.RAI 2.3.4.2-5 Followup Response The current WCGS license basis for Post-Fire Safe Shutdown (PFSSD) includes calculation XX-E-013 "Post-Fire Safe Shutdown Analysis." Appendix 3 to XX-E-013 lists all of the components in scope for PFSSD. Components in the turbine building installed on 1" or under lines are excluded from the components listed in Appendix 3 to XX-E-013 for PFSSD. Therefore, the 1" lines discussed in RAI 2.3.4.2-5 are not components required for PFSSD and are not within the scope of license renewal.Fire Protection System RAI 2.3.3.14-5 Followup Discussion During a telephone conference call on June 14, 2007, the staff indicated that the response to this RAI requires clarification.
The applicant's response lists fire water suppression systems that are not within the scope of license renewal. The staff finds this inconsistent with the WCGS USAR Section 9.5. The staff requested that the applicant justify why these components were not included within the scope of license renewal pursuant to 10 CFR 54.4(a)(3) as some of them are required for compliance with 10 CFR 50.48, and 10 CFR Part 50, Appendix A, Criterion 3 (GDC 3).RAI 2.3.3.14-5 Followup Response The fire water suppression systems that are within the scope of license renewal as identified in RAI 2.3.3.14-5 are the systems required for compliance with IOCFR50.48 and 1OCFR50, Appendix A, Criterion
- 3. The fire water suppression systems that are not within the scope of license renewal as identified in RAI 2.3.3.14-5 are systems that are used only for property protection.
Attachment II to ET 07-0028 Page 1 of 1 LIST OF COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation in this document.
Any other statements in this letter are provided for information purposes and are not considered regulatory commitments.
Please direct questions regarding these commitments to Mr. Kevin Moles, Manager Regulatory Affairs at Wolf Creek Generating Station, (620) 364-4126.COMMITMENT LRA COMMITMENT DESCRIPTION SUBJECT Section 35 LRA Amendment N/A License Renewal Application changes discussed in ET 07-0028 will be submitted in an amendment to the application.
Reference:
ET 07-0028 Due: August 31, 2007