ET 07-0042, Followup Response to NRC Requests for Additional Information Related to License Renewal Application
| ML072770010 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/27/2007 |
| From: | Garrett T Wolf Creek |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ET 07-0042 | |
| Download: ML072770010 (9) | |
Text
- CREEK OPERATING CORPORATION Terry J. Garrett Vice President, Engineering September 27, 2007 ET 07-0042 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Reference:
- 3) Telephone Conference Summary dated August 28, 2007, from V. Rodriguez, USNRC (ML072320452)
Subject:
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 (RAIs) regarding the License Renewal Application. Reference 3 documented a telephone conference call held on August 17, 2007 to discuss and clarify the WCNOC responses. Attachment I provides follow-up responses to the RAIs discussed on the conference call.
Attachment II provides a summary of the commitments made in this response. License renewal commitment number 30 has been revised. provides an updated table of Alloy 600 locations and examinations previously provided in RAI B.2.1.34-6 Followup Response in Reference 2.
P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET
ET 07-0042 Page 2 of 3 If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr.
Kevin Moles at (620) 364-4126.
Sincerely, Terry J. Garrett TJG/rlt Attachments II WCNOC Followup Response to NRC Requests for Additional Information List of Commitments Enclosure 1
Alloy 600 Locations and Examinations cc:
J. N. Donohew (NRC), w/a, w/e E. E. Collins (NRC), w/a, w/e V. G. Gaddy (NRC), w/a, w/e V. Rodriguez (NRC), w/a, w/e Senior Resident Inspector (NRC), wo/a, wo/e
Attachment I to ET 07-0042 Page 1 of 2 Attachment I WCNOC Followup Response to NRC Requests for Additional Information RAI B.2.1.34-1
Attachment I to ET 07-0042 Page 2 of 2 Nickel Alloy Aging Management Program (AMP)
RAI B.2.1.34-1 Followup Discussion During a telephone conference call on August 17, 2007, the staff indicated that the response to this RAI requires clarification. The staff requested that the applicant address the following:
(1) The staff indicated that the applicant's response did not address the steam generator primary nozzle and safe ends. The staff requested that the applicant address this Aging Management Review (AMR) line item.
The applicant indicated that the steam generator primary nozzle and safe ends AMR line items will be modified to provide a clarification.
(2) The staff requested that the applicant clarify if WCGS has Alloy 600 components in the instrumentation nozzles.
The applicant indicated that WCGS only has Alloy 600 in the control rod drive mechanism. The applicant indicated that a footnote will be added to the RAI response to provide a clarification.
(3) The staff requested that the applicant clarify the term "generator maintenance" provided in the table for this RAI response.
The applicant indicated that WCGS performs generator maintenance every refueling outage.
The applicant indicated that a footnote will be added to the RAI response to provide a clarification and details about the generator maintenance frequency.
(4) The staff indicated that the applicant's response did not include the USAR supplement for the Nickel Alloy AMP as requested in the RAI. The staff clarified that the USAR supplement should make reference to the AMP commitment (Commitment No. 30). In addition, the staff indicated that Commitment No. 30 should be supplemented to reflect the same language established in the commitment for pressure boundary nickel alloy components (Commitment No. 19).
RAI B.2.1.34-1 Followup Response (1) The steam generator primary nozzle and safe ends AMR line items were modified in letter ET 07-0038, "Wolf Creek Generating Station License Renewal Application, Amendment 3,"
dated August 31, 2007. See Table 3.1.2-3, "Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Steam Generators," Component Type "SG Primary Nozzles and Safe Ends." Plant specific Note 4 was added to provide clarification.
(2) and (3) Footnotes 3 and 4 have been added to the table provided in Enclosure 1. This table was provided in the Followup Response to RAI B.2.1.34-6 in letter ET 07-0033, "Followup Response to NRC Requests for Additional Information Related to Wolf Creek Generating Station License Renewal Application," dated July 26, 2007.
(4) The USAR supplement for the Nickel Alloy AMP, A1.34, was provided in letter ET 07-0038, "Wolf Creek Generating Station License Renewal Application, Amendment 3," dated August 31, 2007.
Commitment No. 30 has been revised in Attachment II to reflect the same language established in the commitment for pressure boundary nickel alloy components (Commitment No. 19.)
Attachment II to ET 07-0042 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 Station, (620) 364-4126.
Moles, Manager Regulatory Affairs at Wolf Creek Generating COMMITMENT
- LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 30 Nickel Alloy Aging A1.34 The WCNOC Nickel Alloy Aging Management Program Management Program will be supplemented with implementation of (RCMS 2007-251) applicable (1) NRC Orders, Bulletins and Generic Letters associated with nickel alloys and (2) staff-accepted industry guidelines, (3) participate in the industry initiatives, such as owners group programs and the EPRI Materials Reliability Program, for managing aging effects associated with nickel alloys, (4) upon completion of these programs, but not less than 24 months before entering the period of extended operation, WCNOC will submit an inspection plan for reactor coolant system nickel alloy pressure boundary components to the NRC for review and approval.
Upon completion of these supplemental requirements, the WCGS Nickel Alloy Aging Management inspection plan will be submitted for NRC review and approval at least 24 months prior to entering the period of extended operation.
Reference:
ET 07-0016 Due: March 11, 2023 Revised ET 07-0042 to ET 07-0042 Alloy 600 Locations and Examinations (Provided in Letter ET 07-0033, RAI B.2.1.34-6 Followup Response)
Rank Location Type Examination Frequency REACTOR VESSEL COMPONENTS (RV) 12 RV Outlet Nozzle Safe-End-Hot Leg Bare Metal Visual Each Refueling (Bare Volumetric Metal Visual), Every 5 Years (Volumetric) 15 RV Head Vent Nozzle Bare Metal Visual Lesser of 3rd Refueling or 5 Years 17 RV Bottom Mounted Nozzle (BMN)
Bare Metal Visual Every Other Refueling Volumetric (Bare Metal Visual), 10-year ISI Exam (Volumetric) 28 RV BMN Weld Volumetric 10-year ISI Exam 29 RV BMN to Guide Tube Weld VT-2 Each Refueling 30 RV Inlet Nozzle Safe-End (Cold Leg)
Bare Metal Visual Every 3rd Refueling (Bare Weld Volumetric Metal Visual), Every 6 Years (Volumetric) 31 RV Core Support Block at Weld Visual Once per Interval 32 RV Core Support Block Weld Visual Once per Interval 34 RV Core Support Block Visual Once per Interval 35 RV Head Vent to Elbow Weld VT-2 Each Refueling 36 RV Head Vent Elbow to Piping Weld VT-2 Each Refueling 37 RV Head Vent Pipe to SS Elbow VT-2 Each Refueling 39 RV Head Vent Nozzle Elbow VT-2 Each Refueling 40 RV Head Vent Horizontal Pipe VT-2 Each Refueling 21 Head Vent Penetration Weld Volumetric/Surface Lesser of 4th Refueling or 7 Years Control Rod Drive Mechanism (CRDM) Note: 3 13 (CRDM CRDM Nozzle and Nozzle Weld Volumetric/Surface Lesser of 4th Refueling or Nozzle 7 Years Weld) 22 CRDM Nozzle Bare Metal Visual Lesser of 3rd Refueling or 5 Years 38 CRDM to Flange Weld VT-2 Each Refueling PRESSURIZER COMPONENTS (PZR) Note: 1 Mitigated PZR Safety and Relief Nozzle Safe-Volumetric 25% sampling in ISI End Weld interval Mitigated PZR Surge Line Nozzle Safe-End Volumetric 25% sampling in ISI Weld interval Mitigated PZR Spray Nozzle Safe-End Weld Volumetric 25% sampling in ISI interval
Rank I Location I Type Examination Frequency STEAM GENERATOR COMPONENTS (S/G) Note: 4 2
SG Partition Plate-Hot Leg Visual Generator Maintenance 4
SG Partition Stub-Hot Leg Visual Generator Maintenance 5
SG Partition Stub/Tubesheet Weld-Visual Generator Maintenance Hot Leg 6
SG Partition Plate/Stub Weld-Hot Visual Generator Maintenance Leg 8
SG Closure Ring-Hot Leg Visual Generator Maintenance 9
SG Cladding on CS Shell-Hot Leg Visual Generator Maintenance 10 SG Partition Plate/Lower Bowl Weld-Visual Generator Maintenance Hot Leg 11 SG Closure Ring Weld-Hot Leg Visual Generator Maintenance 14 SG Partition Plate-Cold Leg Visual Generator Maintenance 16 SG Partition Stub-Cold Leg Visual Generator Maintenance 18 SG Tubesheet and Radius Cladding-Visual Generator Maintenance Hot Leg 19 SG Partition Stub/Tubesheet Weld-Visual Generator Maintenance Cold Leg 20 SG Partition Plate/Stub Weld-Cold Visual Generator Maintenance Leg 23 SG Closure Ring-Cold Leg Visual Generator Maintenance 24 SG Closure Ring Weld-Cold Leg Visual Generator Maintenance 25 SG Drain Pipe (Tube)
Visual Generator Maintenance 26 SG Cladding on CS Shell-Cold Leg Visual Generator Maintenance 27 SG Partition Plate/Lower Bowl Weld-Visual Generator Maintenance Cold Leg 33 SG Tubesheet and Radius Cladding-Visual Generator Maintenance Cold Leg REACTOR COOLANT PIPING COMPONENTS (RCS)
Unranked RCS Hot Leg Thermowells VT-2 Each Refueling Unranked RCS Cold Leg Thermowells VT-2 Each Refueling ENGINEERED SAFETY FEATURES COMPONENTS (ESF) Note: 2 NR 1 Accumulator Nozzles (All Alloy VT-2 ISI Period 1 82/182 Welds)
Note: 1) The Pressurizer Surge, Safety, Relief and Spray Nozzles have been overlayed with Alloy 690. The pressure boundary in these locations is now the Alloy 690 overlay. The original Alloy 600 is no longer credited as the pressure boundary. Preemptive structural weld overlays immediately go into a sampling pool where 25% of this group must be volumetrically inspected each ISI interval.
Note: 2) As the system/piping temperature is ambient containment temperature (approximately 100 OF), this location is not considered susceptible to Primary Water Stress Corrosion Cracking (PWSCC).
Note:
- 3) The CRDM nozzles include 5 penetrations used for incore thermocouple instrumentation. The materials and general configuration for the instrumentation nozzles is the same as for the CRDM penetrations, and therefore have the same examination requirements as the CRDM.
Note: 4) Generator maintenance includes a generic visual examination of the general condition of non-pressure boundary Alloy 600/82/182 material included in the cladding, divider plate, and other locations in the generator primary side.
This examination is performed when the generator primary side is opened for Steam Generator eddy current testing of the Steam Generator U-tubes.