ML20134N173

Forwards RAI Re Second 10-yr Interval Inservice Program Plan & Associated Requests for Relief from ASME Boiler & Pressure Vessel Code

ML20134N173
Person / Time
Site:	Wolf Creek
Issue date:	11/25/1996
From:	Stone J NRC (Affiliation Not Assigned)
To:	Carns N WOLF CREEK NUCLEAR OPERATING CORP.
References
TAC-M93381, NUDOCS 9611260201
Download: ML20134N173 (5)

Text

. . ~ . . .- . ._. . .- - - . - -. .. . - .- -

.- i, November 25, 1996

^

Mr. Neil S. Carns

' President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 l Burlington, Kansas 66839

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION, SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR

RELIEF, WOLF CREEK GENERATING STATION (TAC NO. M93381)

Dear Mr. Carns:

The NRC staff is continuing to review and evaluate the second ten-year interval inservice inspection program plan and associated requests for relief

~

from the ASME Boiler and Pressure Vessel Code,Section XI requirements for the Wolf Creek Generating Station. Additional information is required from Wolf

Creek Nuclear Operating Corporation in order for the staff to complete its

review.

l Enclosed is a request that details the additional information required for the ,

staff to complete its review. In order to meet the staff's inservice t inspection program plan review schedule, it is requested that a response be  ;

provided within 60 days of receipt of this letter. In addition, to expedite  !

the review process, please send a copy of the RAI response to the NRC's contractor, INEL, at the following address:

Michael T. Anderson INEL Research Center i l

2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, Original signed by:

James C. Stone, Senior Project Manager  ;

Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-482 DISTRIBUTION:

Docket File EPeyton

Enclosure:

Request for Additional PDIV-2 R/F WBateman Information PUBLIC JStone JRoe ACRS cc w/ enc 1: See next page EAdensam TMcLellan, 07-H-15 OGC JDyer,'RIV DOCUMENT NAME: ISIRAI3.WC Q}I (

OFC PDIV-2/PMd PDIV-2/LA NAME JStone:ye Ekyt$

DATE 11/8(/96 11f91/96 g 0FFICIAL RECORD COPY 9611260201 961125

, hhf PDR ADOCK 05000482 G PDR

4 November 25, 1996 I Mr. Neil S. Carns i President and Chief Executive Officer j Wolf Creek Nuclear Operating Corporation l Post Office Box 411

- Burlington, Kansas 66839

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION, SECOND 10-YEAR INTERVAL i

INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF, WOLF CREEK GENERATING STATION (TAC NO. M93381)

Dear Mr. Carns:

The NRC staff is continuing to review and evaluate the second ten-year interval inservice inspection program plan and associated requests for relief from the ASME Boiler and Pressure Vessel Code,Section XI requirements for the Wolf Creek Generating Station. Additional information is required from Wolf Creek Nuclear Operating Corporation in order for the staff to complete its review.

Enclosed is a request that details the additional information required for the staff to complete its review. In order to meet the staff's inservice inspection program plan review schedule, it is requested that a response be provided within 60 days of receipt of this letter. In addition, to expedite the review process, please send a copy of the RAI response to the NRC's contractor, INEL, at the following address:

Michael T. Anderson INEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, Original signed by:

James C. Stone, Senior Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Rea:: tor Regulation Docket No. 50-482 DJSTRIBUTION:

Docket File EPeyton

Enclosure:

Request for Additional PDIV-2 R/F WBateman Information PUBLIC JStone JRoe ACRS cc w/ enc 1: See next page EAdensam TMcLellan, 07-H-15 OGC JDyer, RIV DOCUMENT NAME: ISIRAI3.WC 0FC PDIV-2/PMk PDIV-2/LA NAME JStone:ye EM DATE 11/8(/96 11@l/96 0FFICIAL RECORD COPY

M o

Mr. Neil S. Carns - 2.- ,

cc w/ encl:

Jay Silberg, Esq. Vice President Plant Operations ,

Shaw, Pittman, Potts & Trowbridge Wolf Creek Nuclear Operatin" ' ~. Nn ,

2300 N Street, NW P. O. Box 411 Washington, D.C. 20037 Burlington, Kansas 668' Regional Administrator, Region IV Supervisor Licensing U.S. Nuclear Regulatory Comission Wolf Creek Nuclear Operating Corporation 611 Ryan Plaza Drive, Suite 1000 P.O. Box 411 1

Arlington, Texas 76011 Burlington, Kansas 66839 Senior Resident Inspector U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Resident Inspectors Office l P. O. Box 311 8201 NRC Road  !

Burlington, Kansas 66839 Steedman, Missouri 65077-1032 l Chief Engineer Supervisor Regulatory Compliance Utilities Division Wolf Creek Nuclear Operating Corporation Kansas Corporation Commission P.O. Box 411 1500 SW Arrowhead Road Burlington, Kansas 66839 Topeka, Kansas 66604-4027 Office of the Governor I State of Kansas  !

. Topeka, Kansas 66612 Attorney General Judicial Center 301 S.W. 10th 2nd Floor Topeka, Kansas 66612  ;

County Clerk Coffey County Courthouse Burlington, Kansas 66839 Public Health Physicist '

Bureau of Air & Radiation Division of Environment Kansas Department of Health and Environment Forbes Field Building 283 Topeka, Kansas 66620 i

5 6

e l

1* WOLF CREEK NUCLEAR OPERATING CORPORATION

!. WOLF CREEK GENERATING STATION D0CKET No. 50-482 REQUEST FOR ADDITIONAL INFORNATION

)

l SEC005 10-YEAR INTERVAL INSERVICE INSPECTION PR0lduGI PLAN I

1. Scoce/ Status of Review The Nuclear Regulatory Commission (NRC) is responsible for the review

! and disposition of licensee requests relating to inservice inspection

! requirements contained in the Code of Federal Regulations (CFR)

, 10 CFR 50.55a, and Section XI of the American Society of Mechanical l Engineers' (ASME), Boiler and Pressure Vessel Code. When submitting such requests, licensees are required to provide both a regulatory basis (by citing the appropriate section of 10 CFR 50.55a), and a technical discussion, supporting the request. This information is used in evaluating the request.

The staff has reviewed the available information in the Wolf Creek Generating Station, Second 10-Year Interval inservice Inspection Program Plan, the proposed alternatives to, and requests for relief from, ASME Code Section XI requirements, and additional information submitted by letters dated August 30, 1995 and May 3, 1996.

2. Additional Information Reauired i

The staff has concluded that additional information and/or clarification is required to complete the evaluation. The licensee must state the specific paragraph of the regulations (10 CFR 50.55a) under which the request is submitted and provide supporting justification as discussed below.

The regulations provide that a licensee may propose an alternative to I CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(a)(3)(ii). Pursuant to 10 CFR 50.55a(a)(3)(i), the proposed j alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially, be equivalent to the original requirement in terms of quality and safety. Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Examples of hardship and/or unusual  ;

difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examinations, and development of sophisticated tooling that would result in only minimal increases in examination coverage.

4

o A licensee may also submit a request for relief from ASME requirements.

In accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines 4 that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as  !

specified in 10 CFR 50.4, information to support that determination.

When a licensee determines that an inservice inspection requirement is

, impractical, e.g., the system would have to be redesigned, or a ,

l component would have to be replaced to enable inspection, the licensee should cite 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination requirement.

The staff has concluded that the following specific information and/or clarification is required to complete the review of the ISI Program Plan:

A. Requests 12R-01, 12R-03, 12R-04, 12R-05, 12R-06, 12R-07, 12R-08, l and 12R-18, were submitted pursuant to 10 CFR 50.55a(a)(3)(ii). '

However, the bases for these requests mention " acceptable levels of quality and safety" and " examinations performed to the extent practical . " It is unclear as to which paragraph of 10 CFR 50.55a these requests should be evaluated against. Provide appropriate references to the Code of Federal Regulations and clarify the supporting bases for the subject requests.

B. Requests I2R-14, 12R-19, and I2R-20, were submitted without reference to a section of the Code of Federal Regulations.

Without these references, the subject requests cannot be evaluated. Provide appropriate references to the Code of Federal Regulations and clarify the supporting bases for the subject requests.