ML20035H504
| ML20035H504 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/28/1993 |
| From: | Rhodes F WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TASK-070, TASK-094, TASK-70, TASK-94, TASK-OR ET-93-0054, ET-93-54, GL-90-06, GL-90-6, NUDOCS 9305050164 | |
| Download: ML20035H504 (2) | |
Text
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WQLF CREEK NUCLEAR OPERAUNG CORPORATION
-l April 28, 1993 Forrest T. Rhooes Vice Present Engineenn9 ET 93-0054 U.
S. Nuclear Regulatory Commission
-f ATTN:
Document Control Desk Mail Station P1-137
' 7 Washington, D.
C.
20555
[
I
Reference:
1)
Letter ET 90-0190 dated December 21, 1990 from F.
T.
Rhodes, WCNOC, to NRC 2)
Letter ET 91-0075 dated May 14, 1991 from
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F. T.
Rhodes, WCNOC, to NRC 3)
Letter dated July 30, 1992 from W. D.
Reckley, NRC i
to B.
D. Withers, WCNOC 4)
Letter WM 92-0158 dated October 2, 1992 from I
B.
D. Withers, WCNOC, to NRC
Subject:
Docket No. 50-482:
Change in Commitment Made in Response to Generic Letter 90-06
.i I
Gentlemen:
This letter provides notification of a change in commitment made by Wolf Creek Nuclear Operating Corporation (WCNOC) as part of the response to the NRC's request for additional information on WCNOC's Generic Letter 90-06 submittal, i
This change involves testing the power-operated relief valves (PORV's) during Mode 4 prior to Mode 3 (ascending) every time the plant is placed in Mode 5 for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, not to exceed quarterly testing.
This change was discussed between Mr. Steven G. Wideman, Supervisor Licensing, and others from
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WCNOC, and Mr. William D. Reckley, NRC Project Manager, and others from the NRC on a conference call on April 8, 1993.
Additionally, the discussion determined that a supplement to the license amendment request would not be required.
Generic Letter (GL) 90-06, dated June 25, 1990 was issued to present NRC staff positions on Generic Issue 70 (GI-70), " Power-Operated Relief Valve and Block Valve Reliability," and Generic Issue 94 (GI-94), " Additional Low-Temperature Overpressure Protection for Light-Water Reactors."
WCNOC's original response to-GL 90-06 (Reference 1) stated, for item 2 of the GI-70 issue, that "The PORV's and block valves are included in the NRC approved Inservice Tes ting l
(IST) program. The PORV's are full stroke tested on a cold shutdown frequency with the block valve open in accordance with the IST program. and WCGS Technical Specifications." A separate Technical Specification 3/4.4.4, Relief Valves and 3.4.9.3, overpressure Protection System, change was submitted on May 14, 1991 (Reference 2) to complete WCNOC's response to GL 90-06.
The NRC notified WCNOC on July 30, 1992 (Reference 3) that selected portions of Reference 1 were not acceptable and that a resubmittal would be required to provide a response that met the intent of the GL.
Specifically the NRC stated that "The staff is not accepting Mode 5 (COLD SHUTDOWN) testing simply because it is allowable by the ASME Code or that the NRC approved IST program includes Mode 5 for this particular test."
04011:7 PO Box 411/ Burlington, KS 66839 / Phone: (316) 364-8831 h
9305050164 930428 An equ,,oppo,,,n,,,empioyo,M/UHC/ VET PDR ADOCK 05000482 P
PDR Li
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ET 93 0054 Page 2 of 2 f
WCNOC provided the required resubmittal on October 2, 1992-(Reference 4) which modified Reference 1 to state that WCNOC will full stroke test the PORV's prior to cooldown below 36B'F.
This surveillance test would be conducted f
during Mode 3 operation, consistent with the staff's position to ensure FORV l
operability for purposes of low temperature overpressure protection.
WCNOC l
also committed in this submittal to supplement the license amendment request to Technical Specifications 3/4.4.4 and 3.4.9.3 to reflect the changes made to the response to item 2 by April 30, 1993.
j i
WCNOC has performed additional reviews of the responses to this GL and the current testing methodology for the PORV's.
Based upon this review, WCNOC
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intends to full stroke test the PORV's during Mode 4 prior to Mode 3 (ascending) every time the plant is placed in Mode 5 - for greater than 72 j
hours, not to exceed quarterly testing.
This testing will be performed in i
Mode 4 ascending to avoid testing following shutdown when decay heat load is the greatest.
This surveillance testing, which demonstrates the operability
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of the PORV's, remains valid for up to 18 months and maintains the valves as i
operable prior to establishing conditions where the PORV's are used for' low temperature overpressure protection. WCHOC intends to perform this testing in
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this manner while returning to Power Operation from the current refueling i
outage.
During the period from the original response to the present, testing i
of the PORV's was performed in accordance with WCNOC's GL response and' commitments in affect at the time.
Based upon the discussions with the NRC
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staff, testing of the PORV's in this manner meets the intent of the GL.
If you have any questions concerning this change in commitment, please contact f
me at (316) 364-8831 extension 4002 or Mr. Kevin J. Moles at extension 4565.
Very truly yours, Forrest T.
Rhodes l
Vice President Engineering i
FTR/jad cc:
W.
D. Johnson (NRC) i J. L. Milhoan (NRC)
.l G. A. Pick (NRC)
W.
D.
Reckley (NRC) r I
E s
i 1
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