ET 08-0024, Operating Corporation - Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion to Technical Specification 5.5.9, Steam Generator (SG) Program

Operating Corporation - Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion to Technical Specification 5.5.9, Steam Generator (SG) Program

ML081000126
Person / Time
Site:	Wolf Creek
Issue date:	03/30/2008
From:	Garrett T Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 08-0024
Download: ML081000126 (5)

Text

WSLF CREEK ?NUCLEAR OPERATING CORPORATION Terry J. Garrett March 30, 2008 Vice President, Engineering ET 08-0024 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

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

2) Letter ET 08-0016, dated March 21, 2008, from T. J. Garrett, WCNOC, to USNRC

Subject:

Docket No. 50-482: Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion to Technical Specification 5.5.9, "Steam Generator (SG) Program" Gentlemen:

Reference 1 provided Wolf Creek Nuclear Operating Corporation's (WCNOC) application to revise Technical Specification (TS) 5.5.9, "Steam Generator (SG) Program," that proposed a one cycle revision to incorporate an interim alternate repair criterion (IARC) in the provisions for SG tube repair criteria during Refueling Outage 16 and the subsequent operating cycle.

Reference 2 provided WCNOC's response to the Nuclear Regulatory Commission (NRC).

request for additional information (RAI) provided by electronic mail on February 28, 2008, including four additional questions that were provided to Southern Nuclear Operating Company by electronic mail on March 10, 2008.

In the response to question 13 in Reference 2, WCNOC indicated that an administrative limit would be established to not exceed the calculated steam line break leakage value. On March 26, 2008, during a teleconference with the NRC Project Manager, it was identified that a regulatory commitment was required since the NRC safety evaluation for the requested amendment was relying on the use of a constant multiplier of 2.5 to calculate a steam line break administrative limit. Attachment I provides additional details.

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

ET 08-0024 Page 2 of 3 The additional information provided in the Attachments does not impact the conclusions of the No Significant Hazards Consideration provided in Reference 1. In accordance with 10 CFR 50.91, a copy of this submittal is being provided to the designated Kansas State official.

Attachment II contains a list of regulatory 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, Terry J. Garrett TJG/rlt Attachment I - Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion II - List of Regulatory Commitments cc: E. E. Collins (NRC), w/a T. A. Conley (KDHE), w/a J. N. Donohew (NRC), w/a V. G. Gaddy (NRC), w/a B. K. Singal (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 08-0024 Page 3 of 3 STATE OF KANSAS )

SS 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.

Byy _

Terry J. G'aeft Vice President Engineering SUBSCRIBED and sworn to before me this day of N" ,PC-h , 2008.

S...* .*-

SOFFICIAL:

RHONDA L.TIEMEYER MY COMMISSION EXPIRES Notary Public

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.. SEA - M January 11, 2010 Expiration Date 0'2b JL /.ci, /6

Attachment I to ET 08-0024 Page 1 of 1 Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion Reference 1 provided Wolf Creek Nuclear Operating Corporation's (WCNOC) application to revise Technical Specification (TS) 5.5.9, "Steam Generator (SG) Program," that proposed a one cycle revision to incorporate an interim alternate repair criterion (IARC) in the provisions for SG tube repair criteria during Refueling Outage 16 and the subsequent operating cycle.

Reference 2 provided WCNOC's response to the Nuclear Regulatory Commission (NRC) request for additional information (RAI) provided by electronic mail on February 28, 2008, including four additional questions that were provided to Southern Nuclear Operating Company by electronic mail on March 10, 2008.

In the response to question 13 in Reference 2, WCNOC indicated that an administrative limit would be established to not exceed the calculated steam line break leakage value. On March 26, 2008, during a teleconference with the NRC Project Manager, it was identified that a regulatory commitment was required since the NRC safety evaluation for the requested' amendment was relying on the use of a constant multiplier of 2.5 to calculate a steam line break administrative limit. Specifically, the response to question 13 stated, in part:

For integrity assessments, the ratio of 2.5 will be used in the completion of both the condition monitoring (CM) and operational assessment (OA) upon implementation of the IARC. For example, for the CM assessment, the component of leakage from the lower 4 inches for the most limiting steam generator during the prior cycle of operation will be multiplied by a factor of 2.5 and added to the total leakage from any other source and compared to the allowable accident analysis leakage assumption. For the OA, the difference in leakage from the allowable limit during the limiting design basis accident minus the leakage from the other sources will be divided by 2.5 and compared to the observed leakage. An administrative limit will be established to not exceed the calculated value.

As such, WCNOC considers the above to be a regulatory commitment.

References:

1. WCNOC letter ET 08-0009, "Revision to Technical Specification (TS) 5.5.9, "Steam Generator (SG) Program" for Interim Alternate Repair Criteria," February 8, 2008.

2. WCNOC letter ET 08-0016, "Response to Request for Additional Information Related to License Amendment Request for an Interim Alternate Repair Criterion to Technical Specification 5.5.9, "Steam Generator (SG) Program"," March 21, 2008.

Attachment II to ET 08-0024 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by WCNOC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Richard Flannigan at (620) 364-4117.

COMMITMENT +

I Due Date/Event For integrity assessments, the ratio of 2.5 will be used in the A CM Report and completion of both the condition monitoring (CM) and preliminary OA will operational assessment (OA) upon implementation of the be prepared prior to IARC. For example, for the CM assessment, the component MODE 4 of leakage from the lower 4 inches for the most limiting steam generator during the prior cycle of operation will be multiplied by a factor of 2.5 and added to the total leakage from any other source and compared to the allowable accident analysis leakage assumption. For the OA, the difference in leakage from the allowable limit during the limiting design basis accident minus the leakage from the other sources will be divided by 2.5 and compared to the observed leakage. An administrative limit will be established to not exceed the calculated value.