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MONTHYEARET 10-0019, CFR 50.55a Request for Alternative to ASME Code Case N-579, Use of Nonstandard Nuts, Class 1, 2, and 3, Mc, CS Components and Supports Construction Section III, Division 1.2010-06-10010 June 2010 CFR 50.55a Request for Alternative to ASME Code Case N-579, Use of Nonstandard Nuts, Class 1, 2, and 3, Mc, CS Components and Supports Construction Section III, Division 1. Project stage: Request ML1020400142010-07-23023 July 2010 Acceptance Review, Request for Alternative to ASME Code Case N-579, Use of Nonstandard Nuts, Class 1, 2, and 3, Mc, CS Components and Supports Construction, Section III, Division 1. Project stage: Acceptance Review ML1029901322010-11-18018 November 2010 Request for Alternative to ASME Code Case N-579 on Use of Nonstandard Hydraulic Nuts on the Excess Letdown Heat Exchanger Project stage: Other 2010-06-10
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Category:Letter type:ET
MONTHYEARET 23-0006, CFR 50.55a Request Number CI3R-01 for the Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded Post-Tensioning System Components2023-05-17017 May 2023 CFR 50.55a Request Number CI3R-01 for the Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded Post-Tensioning System Components ET 23-0005, 10 CFR 50.55a Request Number I4R-08 for the Fourth Inservice Inspection Program Interval, Relief for Extension of Follow Up Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peen2023-03-16016 March 2023 10 CFR 50.55a Request Number I4R-08 for the Fourth Inservice Inspection Program Interval, Relief for Extension of Follow Up Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened ET 23-0003, License Amendment Request (LAR) for Removal of the Power Range Neutron Flux Rate - High Negative Rate Trip Function from Technical Specifications2023-03-0101 March 2023 License Amendment Request (LAR) for Removal of the Power Range Neutron Flux Rate - High Negative Rate Trip Function from Technical Specifications ET 23-0002, Supplement to License Amendment Request to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections2023-02-0707 February 2023 Supplement to License Amendment Request to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ET 23-0004, Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements2023-01-26026 January 2023 Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements ET 22-0006, Operating Corp. - Application to Revise Technical Specifications to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections2022-12-0101 December 2022 Operating Corp. - Application to Revise Technical Specifications to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ET 22-0010, License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements2022-08-0202 August 2022 License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements ET 22-0012, Supplement to License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating2022-07-12012 July 2022 Supplement to License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating ET 22-0011, Withdrawal of 10 CFR 50.55a Request I4R-08, Relief for Extension of Follow-up Examination and Visual Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surface2022-05-31031 May 2022 Withdrawal of 10 CFR 50.55a Request I4R-08, Relief for Extension of Follow-up Examination and Visual Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surface ET 22-0005, Response to Request for Additional Information Regarding License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating2022-04-13013 April 2022 Response to Request for Additional Information Regarding License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating ET 22-0003, CFR 50.55a Request I4R-09 for the Fourth Inservice Inspection Program Interval, Relief from Examination of Reactor Vessel Flange Threads2022-04-0606 April 2022 CFR 50.55a Request I4R-09 for the Fourth Inservice Inspection Program Interval, Relief from Examination of Reactor Vessel Flange Threads ET 22-0002, Operating Corp 10 CFR 50.55a Request Number I4R-08 for the Fourth Inservice Inspection Program Interval, Relief for Extension of Follow Up Examination and Visual Examination Requirements for Reactor Pressure Vessel Head .2022-04-0404 April 2022 Operating Corp 10 CFR 50.55a Request Number I4R-08 for the Fourth Inservice Inspection Program Interval, Relief for Extension of Follow Up Examination and Visual Examination Requirements for Reactor Pressure Vessel Head . ET 22-0004, Operating Corp - Response to Request for Confirmation of Information (RCI) Regarding Steam Generator Tube Inspection Report2022-03-15015 March 2022 Operating Corp - Response to Request for Confirmation of Information (RCI) Regarding Steam Generator Tube Inspection Report ET 22-0001, Removal of the Table of Contents from the Technical Specifications2022-01-12012 January 2022 Removal of the Table of Contents from the Technical Specifications ET 21-0017, Response to Request for Additional Information Regarding License Amendment Request - Revision to Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation2021-12-22022 December 2021 Response to Request for Additional Information Regarding License Amendment Request - Revision to Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ET 21-0009, Results of the Steam Generator Tube Inservice Inspection During the 24th Refueling Outage2021-11-0101 November 2021 Results of the Steam Generator Tube Inservice Inspection During the 24th Refueling Outage ET 21-0015, Withdrawal of License Amendment Request for a Risk-Informed Resolution to GSI-1912021-10-20020 October 2021 Withdrawal of License Amendment Request for a Risk-Informed Resolution to GSI-191 ET 21-0012, Supplement to License Amendment Request for a Risk-Informed Resolution to GSI-1912021-10-11011 October 2021 Supplement to License Amendment Request for a Risk-Informed Resolution to GSI-191 ET 21-0004, License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating2021-09-29029 September 2021 License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating ET 21-0010, License Amendment Request - Revision to Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation2021-09-29029 September 2021 License Amendment Request - Revision to Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ET 21-0005, Operating Corp., License Amendment Request for a Risk-Informed Resolution to GSI-1912021-08-12012 August 2021 Operating Corp., License Amendment Request for a Risk-Informed Resolution to GSI-191 ET 20-0013, Response to Request for Additional Information Re Application for Technical Specification Change Re Risk-Informed Justification for Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program (TSTF-415)2020-10-26026 October 2020 Response to Request for Additional Information Re Application for Technical Specification Change Re Risk-Informed Justification for Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program (TSTF-415) ET 20-0011, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2020-10-0101 October 2020 Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI ET 20-0007, License Amendment Request for Replacement of Engineered Safety Features Transformers with New Transformers That Have Active Automatic Load Tap Changers2020-06-0808 June 2020 License Amendment Request for Replacement of Engineered Safety Features Transformers with New Transformers That Have Active Automatic Load Tap Changers ET 20-0008, Operating Corporation Update for Full Implementation of Open Phase Detection System2020-05-20020 May 2020 Operating Corporation Update for Full Implementation of Open Phase Detection System ET 20-0004, Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)2020-04-27027 April 2020 Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425) ET 20-0002, Response to Request for Additional Information Regarding Utilizing Code Case N-666-1, Weld Overlay of Class 1, 2, and 3 Socket Welded Connections, Section XI, Division 12020-01-29029 January 2020 Response to Request for Additional Information Regarding Utilizing Code Case N-666-1, Weld Overlay of Class 1, 2, and 3 Socket Welded Connections, Section XI, Division 1 ET 19-0021, Errata for Supplemental Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation2019-12-0909 December 2019 Errata for Supplemental Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation ET 19-0020, Supplemental Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation2019-11-13013 November 2019 Supplemental Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation ET 19-0019, Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.2019-09-10010 September 2019 Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation. ET 19-0018, Supplement to License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.2019-08-22022 August 2019 Supplement to License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation. ET 19-0014, lnserv1ce Inspection (ISI) Program Relief Request Number 14R-07, to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, D1v1s1on 12019-08-15015 August 2019 lnserv1ce Inspection (ISI) Program Relief Request Number 14R-07, to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, D1v1s1on 1 ET 19-0002, License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.2019-03-18018 March 2019 License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation. ET 19-0008, Response to Request for Additional Information Related to Thermal Conductivity Degradation for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption.2019-03-0505 March 2019 Response to Request for Additional Information Related to Thermal Conductivity Degradation for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption. ET 19-0003, License Amendment Request to Revise Technical Specification 3.6.3 and Surveillance Requirement 3.6.3.1 to Remove Use of a Blind Flange2019-02-25025 February 2019 License Amendment Request to Revise Technical Specification 3.6.3 and Surveillance Requirement 3.6.3.1 to Remove Use of a Blind Flange ET 19-0001, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 42019-01-23023 January 2019 Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4 ET 18-0032, Operating Corporation Change of Date for Full Implementation of Open Phase Detection System2018-12-0707 December 2018 Operating Corporation Change of Date for Full Implementation of Open Phase Detection System ET 18-0035, Operating Corp., Supplemental Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-12-0606 December 2018 Operating Corp., Supplemental Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term ET 18-0029, (WCGS) - Results of the Twenty First Steam Generator Tube Inservice Inspection2018-10-31031 October 2018 (WCGS) - Results of the Twenty First Steam Generator Tube Inservice Inspection ET 18-0018, Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-06-19019 June 2018 Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term ET 18-0016, Response to Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools Request for Supplemental Information2018-05-29029 May 2018 Response to Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools Request for Supplemental Information ET 18-0014, Response to Request for Additional Information Regarding the License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.2018-05-29029 May 2018 Response to Request for Additional Information Regarding the License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System. ET 18-0013, Relief Request Number I4R-06, Request for Relief from ASME Code Case N-729-4 for Reactor Vessel Head Penetration Nozzle Weld2018-05-0202 May 2018 Relief Request Number I4R-06, Request for Relief from ASME Code Case N-729-4 for Reactor Vessel Head Penetration Nozzle Weld ET 18-0011, (WCGS) - Guarantee of Payment of Deferred Premiums2018-04-30030 April 2018 (WCGS) - Guarantee of Payment of Deferred Premiums ET 18-0012, Operating Corp., Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-04-19019 April 2018 Operating Corp., Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term ET 18-0010, Financial Protection Levels2018-03-29029 March 2018 Financial Protection Levels ET 18-0007, Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.2018-02-15015 February 2018 Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System. ET 18-0005, Withdrawal of License Amendment Request for Revision to the Emergency Plan2018-02-0505 February 2018 Withdrawal of License Amendment Request for Revision to the Emergency Plan ET 18-0004, Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-01-29029 January 2018 Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term ET 17-0025, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term2017-11-14014 November 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term 2023-05-17
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WLF CREEK
'NUCLEAR OPERATING CORPORATION June 10, 2010 Terry J. Garrett Vice President Engineering ET 10-0019 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Docket 50-482: 10 CFR 50.55a Request for Alternative to ASME Code Case N-579, "Use of Nonstandard Nuts, Class 1, 2, and 3, MC, CS Components and Supports Construction Section III, Division 1" Gentlemen:
Pursuant to 10 CFR 50.55a(a)(3)(i), Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests Nuclear Regulatory Commission (NRC) approval of the attached 10 CFR 50.55a Request for the Third Ten-Year Interval of WCNOC's Inservice Inspection (ISI) Program.
The attached 10 CFR 50.55a Request proposes an alternative to the requirements of ASME Boiler and Pressure Vessel Code,Section III, Code Case N-579, "Use of Nonstandard Nuts, Class 1, 2, and 3, MC, CS Components and Supports Construction Section III, Division 1." The proposed alternative provides an acceptable level of quality and safety as required by 10 CFR 50.55a(a)(3)(i).
WCNOC requests approval of the attached 10 CFR 50.55a Request by December 30, 2010, to support planning for Refueling Outage 18, which is scheduled to begin in March, 2011.
P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET
ET 10-0019 Page 2 of 2 There are no commitments contained within this letter. If you have any questions, please contact me at (620) 364-4084 or Mr. Richard Flannigan at (620) 364-4117.
Sincerely, Terry J. Garrett TJG/rlt
Attachment:
10 CFR 50.55a Request cc: E. E. Collins (NRC), w/a G. B. Miller (NRC), w/a B. K. Singal (NRC), w/a Senior Resident Inspector (NRC), w/a
Attachment to ET 10-0019 Wolf Creek Nuclear Operating Corporation 10 CFR 50.55a Request Alternative to the requirements of ASME Boiler and Pressure Vessel Code,Section III, Code Case N-579
Attachment to ET 10-0019 Page 1 of 2 10 CFR 50.55a Request Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
Alternative Provides Acceptable Level of Quality and Safety
- 1. ASME Code Components Affected The Excess Letdown Heat Exchanger (EBG02) channel head joint flange-bolting replacement (ASME Class 2).
- 2. Applicable Code Edition and Addenda The bolting replacement will be performed as a repair/replacement activity under the jurisdiction of the ASME Boiler and Pressure Vessel Code, Section X1. The 1998 Edition through the 2000 Addenda is the applicable Section XI edition and addenda for Wolf Creek Nuclear Operating Corporation's (WCNOC's) third inservice inspection interval.
Section Xl IWA-4000 requires use of portions of the original Construction Code and allows use of Construction Code, Code Cases. For the Excess Letdown Heat Exchanger, the applicable Construction Code is ASME Section III, 1974 Edition including Summer 1975 Addendum.
Code Case N-579, "Use of Nonstandard Nuts, Class 1, 2, and 3, MC, CS Components and Supports Construction Section III, Division 1," is approved for use by the Nuclear Regulatory Commission (NRC) as documented in Regulatory Guide 1.84, "Design, Fabrication, and Materials Code Case Acceptability, ASME Section III," Revision 34, dated October 2007.
- 3. Applicable Code Requirement Relief is requested from the ASME Section Xl repair/replacement activity requirements for the replacement bolting in accordance with Code Case N-579. The specific requirements in Code Case N-579 for which relief is requested are the use of SA-194 material specified in Code Case N-579 for the nonstandard hydraulic nuts and conformance of thread configuration to ASME BI.1.
- 4. Reason for Request The excess letdown heat exchanger flange is located in a high radiation area in the reactor coolant loop 4 area inside the secondary shield wall of the reactor building. The excess letdown heat exchanger flange has had chronic boric acid leakage at various times. Prior efforts to stop the leakage with gasket replacement and bolt torquing adjustments have not been successful and have caused unnecessary radiation exposure to maintenance personnel. The joint is being redesigned to use hydraulic tensioning nuts (HydraNuts) to assure consistent loading around the joint as well as to reduce personnel exposure by reducing maintenance time in the area.
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Attachment to ET 10-0019 Page 2 of 2
- 5. Proposed Alternative and Basis for Use SA-540 Grade B23 material meeting the requirements for bolting material in Section III, paragraph NC-2127(a), will be used to fabricate the hydraulic nuts for the excess letdown heat exchanger flange instead of the SA-1 94 material specified in Code Case N-579. No torque wrench is required for installation since HydraNuts employ a stud tensioning process that tensions all twelve (12) studs simultaneously. The hydraulic nuts will incorporate a proprietary outside thread design providing minimized thread deflection to maximize retained load and allow lower preload to be used in contrast to standard threads manufactured in accordance with ASME B13.1.
ASME SA-540 Grade B23 material, which is an approved Section III material for Class 2 bolting and has sufficient strength for the application, will be used instead of SA-194 for manufacture of the hydraulic nuts.
Code Case N-579 requires the screw threads of nonstandard nuts be manufactured to meet the requirements for threads in ASME B1.1. While the inside threads of the hydraulic nuts conform to ASME B1.1, the outside threads have a proprietary thread design developed by the vendor, Nova-Technofast, which minimizes thread deflection between the nut and lock ring and thereby minimizes loss of pre-load.
Basis for Use Use of Section III approved SA-540 Grade B23 material in lieu of the SA-194 material specified in Code Case N-579 will assure adequate strength in the joint. The special thread design of the outside threads of the hydraulic nuts minimizes thread deflection and loss of preload. Use of these nonstandard nuts is expected to eliminate leakage from the joint while reducing radiation exposure to maintenance personnel by reducing maintenance time in the area. These advantages provide an equivalent level of quality and safety in accordance with 10CFR50.55a(a)(3)(i).
- 6. Duration of Proposed Alternative This relief request will be implemented during the Wolf Creek Generating Station (WCGS) refueling outage number 18 and will remain permanently installed in the plant.
This is a new request based on approved Code Case N-579.
- 7. Precedents A similar request was granted for Diablo Canyon Power Plant (ML040560538). PG&E Letter DCL-04-016, Dated February 12, 2004, to USNRC: Docket Nos. 50-275 and 50-323, Diablo Canyon Units 1 and 2, "Inservice Inspection Relief Request for ASME Code Case N-579," and the associated NRC Safety Evaluation (SE) dated July 29, 2004. The PG&E Relief Request asked for approval to use hydraulic nuts developed by Nova-Technofast for their excess letdown heat exchanger. The NRC SE found the use of SA-540 Grade B23 material acceptable because it is listed as an acceptable material for Class 2 bolting in Section III of the Code. The NRC also found the use of the proprietary outside thread design acceptable because the design minimizes thread deflection between the nut and lock ring and thus the loss of pre-load is minimized.
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