ML073300464
| ML073300464 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/30/2007 |
| From: | Donohew J NRC/NRR/ADRO/DORL/LPLIV |
| To: | Muench R Wolf Creek |
| Donohew J N, NRR/DORL/LPL4, 415-1307 | |
| References | |
| GL-03-001, TAC MB9873 | |
| Download: ML073300464 (5) | |
Text
November 30, 2007 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839
SUBJECT:
WOLF CREEK GENERATING STATION - RESPONSES TO GENERIC LETTER 2003-01, CONTROL ROOM HABITABILITY (TAC NO. MB9873)
Dear Mr. Muench:
By letter dated June 12, 2003, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2003-01, Control Room Habitability, to (1) alert all holders of operating licenses for nuclear reactor power facilities of the findings at U.S. power reactor facilities suggesting that the control room licensing and design bases, and applicable regulatory requirements may not be met, and that existing technical specification surveillance requirements may not be adequate, (2) emphasize the importance of reliable, comprehensive surveillance testing to verify control room habitability, (3) request the licensees to submit information that demonstrates that their facility control rooms comply with the current facility licensing and design bases, and applicable regulatory requirements, and that suitable design, maintenance and testing control measures are in place for maintaining this compliance, and (4) collect the requested information to determine if additional regulatory action is required.
The NRC acknowledges the receipt of your responses to GL 2003-01 dated August 8, 2003, November 16, 2004, February 21, 2005, and June 29 and September 28, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML032260631, ML043280496, ML050600398, ML071910244, and ML072770291, respectively), for Wolf Creek Generating Station (WCGS).
The GL requested that you confirm that your control room meets the applicable habitability regulatory requirements (e.g., General Design Criteria (GDC) 1, 3, 4, 5, and 19, draft GDC, or principal design criteria), with special attention to the following: (1) determination of the most limiting unfiltered and/or filtered inleakage into the control room and comparison to values used in your facility design bases for meeting control room operator dose limits from accidents (GL 2003-01, Item 1a); (2) determination that the most limiting unfiltered inleakage is incorporated into your hazardous chemical assessments (GL 2003-01, Item 1b); and (3) determination that reactor control capability is maintained in the control room or at the alternate shutdown location in the event of smoke (GL 2003-01, Item 1b). The GL further requested information on any compensatory measures in use at your facility to demonstrate control room habitability, and the plans to retire them (GL 2003-01, Item 2).
R. A. Muench In your August 8, 2003, letter, you indicated that you were pursuing an alternate Control Room Envelope (CRE) inleakage testing method because, as was stated in the letter, the GL-identified method (i.e., American Society for Testing and Materials (ASTM) E 741-00, Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution) would not provide valid results for the WCGS CRE design. Your letter of November 16, 2004, indicated that you had performed an alternate method tracer gas test on August 14-16, 2004 and provided preliminary results. Your letter of February 21, 2005, provided the results of the Brookhaven National Laboratory-developed Atmospheric Tracer Depletion (ATD) test. You determined that the maximum tested value of CRE unfiltered inleakage in the emergency/
pressurization mode was 10.5 cubic feet per minute (cfm) and Control Building unfiltered inleakage was 63 cfm, which were in general agreement with your WCGS dose analysis assumptions.
In your September 28, 2007, letter, you provided the 12 types of information identified in Regulatory Guide (RG) 1.197, Demonstrating Control Room Envelope Integrity At Nuclear Power Reactors, Regulatory Position C.1.3 as being needed for the staff to assess the capability and thus acceptability of an alternate test method for determining your CRE inleakage.
In this information you included details of testing performed at another nuclear plant that demonstrated a correlation in results between ASTM E 741 method and ATD method tests that met the comparability standard of RG 1.197, Regulatory Position 1.2. Although the correlation testing described did not consider a configuration with the unique Control Building/Control Room design of WCGS and how non-conservative an ASTM E 741 method test result might be relative to the ATD method used at WCGS, the NRC staff reviewed the information you provided and determined that for your design of Control Building pressurization/filtration and Control Room pressurization/filtration, the ATD method test as you described is consistent with the guidance of RG 1.197 and the NRC staff concludes that the ATD method is acceptable for WCGS.
In your letters previously identified, you also provided information that there were currently no onsite or offsite storage or transportation of chemicals that would pose a credible threat to CRE habitability at WCGS. You also indicated that your chemical control program was being revised to incorporate features necessary to maintain control of hazardous chemicals with respect to CRE habitability, and made regulatory commitments to work with the State of Kansas to obtain survey information regarding offsite mobile chemical sources and update the onsite and offsite hazardous chemical assessments in accordance with RG 1.78, Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release.
Additionally, your letters stated that you had an evaluation performed to confirm reactor control capability from either the control room or the alternate shutdown panel in the event of smoke, and confirmed that WCGS met the Appendix A guidance of Nuclear Energy Institute 99-03, Control Room Habitability Assessment Guidance. The NRC staff finds these responses and commitments for actions are an acceptable response to Item 1(b) of GL 2003-01.
In your February 21, 2005, response letter, you indicated that you would submit a license amendment request (LAR) to revise your technical specifications for implementing Technical Specification Task Force Traveler (TSTF)-448, Control Room Habitability, as appropriate.
R. A. Muench The information you provided in your responses to the GL appears to support your position that no compensatory measures need to be in place to demonstrate control room habitability and that you are committed to meet the General Design Criteria of Title 10 of the Code of Federal Regulations, Part 50, Appendix A, regarding control room habitability at WCGS.
The information provided above and your commitment to submit a LAR based on TSTF-448 is acceptable for purposes of closing out your response to GL 2003-01.
Sincerely,
/RA/
Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482 cc: See next page
ML073300464 OFFICE NRR/LPL4/PM NRR/LPL4/LA DPR/PGCB/BC DSS/SCVB/BC NRR/LPL4/BC NAME JDonohew JBurkhardt MMurphy RDennig THiltz DATE 11/29/07 11/27/07 11/29/07 11/29/07 11/30/07 Wolf Creek Generating Station cc:
Jay Silberg, Esq. Chief, Radiation and Asbestos Control Pillsbury Winthrop Shaw Pittman LLP Section 2300 N Street, NW Kansas Department of Health Washington, D.C. 20037 and Environment Bureau of Air and Radiation Regional Administrator, Region IV 1000 SW Jackson, Suite 310 U.S. Nuclear Regulatory Commission Topeka, KS 66612-1366 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corporation Senior Resident Inspector P.O. Box 411 U.S. Nuclear Regulatory Commission Burlington, KS 66839 P.O. Box 311 Burlington, KS 66839 Supervisor Licensing Wolf Creek Nuclear Operating Corporation Chief Engineer, Utilities Division P.O. Box 411 Kansas Corporation Commission Burlington, KS 66839 1500 SW Arrowhead Road Topeka, KS 66604-4027 U.S. Nuclear Regulatory Commission Resident Inspectors Office/Callaway Plant Office of the Governor 8201 NRC Road State of Kansas Steedman, MO 65077-1032 Topeka, KS 66612 Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597 County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839