ML20199C232

Discusses Info Pertaining to Submitting 120-day Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions, for Wolf Creek Generating Station

ML20199C232
Person / Time
Site:	Wolf Creek
Issue date:	11/12/1997
From:	Thomas K NRC (Affiliation Not Assigned)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
GL-96-06, GL-96-6, TAC-M96887, NUDOCS 9711190272
Download: ML20199C232 (4)

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• j NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 306tH001

...../ November 12, 1997 e Mr. Otto L. Haynard President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, Kansas 66839

SUBJECT:

INFORMATION PERTAINING TO WOLF CREEK GENERATING STATION IMPLEMENTATION OF H0DIFICATIONS ASSOCIATED WIT 11 GENERIC LETTER 96 06. ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN BASIS ACCIDENT CONDIT10NS" (TAC NO M96887)

Dear Mr. Haynard:

The staff issued Generic Letter (GL) 96-06 on September 30, 1996. The generic letter requested licensees to determine (1) if containment air cooler cooling water systems are susceptible to either waterhammer or two phase flow conditions during postulated accident conditions, and (2) if piping systems ~

that penetrate the containment are susceptible to thermal expansion of fluid so that over>ressurization of piping could occur. By letter dated January 29, 1997 you su)mitted your 120 day response to GL 96 06. The staff is currently performing a detailed review of your response.

Implenenting corrective actions to resolve the GL 96-06 issues can have a significant impact on outage schedules and resources. Some licensees have indicated that it would be prudent to take more time to better understand the specific concerns that have been identified in order to optimize whatever actions are needed and to assure that they do not ultimstely result in a detriment to safety. Current issues and ongoing efforts that could influence a licensee's decision in planning corrective actions include (1) risk implications of installing relief valves to deal with the thermal overpressurization issue. (2) feasibility of using the acceptance criteria contained in Appendix F to Section 111 of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for the permanent resolution of the GL 96 06 issues. (3) ongoing tests by the Electric Power Research Institute to support a generic resolution of the overpressurization of piping issue, and (4) questions regarding the staff's closure of Generic Safety Issue 16(, *0verpressurization of Containment Penetrations." Risk insights and industry initiatives that are being considered or that may be proposed could also influence the course of action that licensees take to resolve the GL 96 06 issues.

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l Mr. Otto L. Maynard 2- November 12, 1997 Licensees are res)onsible for assessing equipment operability, determining ,

actions, and esta)lishirq schedules that are appropriate for resolving the specific conditions that have been 1dentified. In determining the appropriate  !

actions and schedules for resolving GL 96 06 issues, licensees should ,

conside,*, for example, the continued validity of existing operability determinations compensatory actions required to maintain operability the  !

safety simificance associated with the s)ecific nonconformances or degraded .

conditions that have been identified, r15.c insights, and the time required to complete any generic initiatives and/or plant specific actions (e.g.,

engineering evaluations, design change packages, material procurement, and equipment modification and installation). Also, analytical solutions employing the permanent use of the acceptanc? criteria contained in the ASME -

Code. Section 111. Appendix F (or other acceptance criteria) may present  !

viable alternatives to plant mod'.fications and can be used where appropriate, ,

justified, and evaluated in accordance with NRC requirements such as '

10 CFR 50.59, as applicable. Licensees may find the revised guidance contained in GL 9118. "Irformation to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability." Revision 1. dated October 8, 1997, helpful in determining appropriate actions and schedules. Although adjustments in schedules may be warranted on the basis of these (and other) :onsiderations specific actions that have been defined and are clearly needed should not be delayed without suitablejt'stification.

L lt is the staff's current position that licensees can use the ASME Code.

Section 111. Appendix F criteria for interim operability determinations for degraded ar.J nonconforming piping and 31pe supports until permanent actions 4

have been identified and approved by tie NRC-(as applicable) for resolving the GL 96 06 issues. This guidance supplements the guidance provided by GL 91-18 for resolution of the GL 96-06 issues, in order to further facilitate resolution of the GL 96 06 issues, the NRC will participate in a )ublic worksho) on this topic later this fall. The worksho proceedings will ?e summarized )y the NRC staff and made publicly available.p The need for additional NRC guidance and generic communication will be considered upon completion of the workshop.

If you choose to revise your commitments for resolving the GL 9C-06 issues, you should submit a revised response to the generic letter. Your revised response should include appropriate discussion of the considerations f

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- Mr.' Otto L. Maynard November 12, 1997 discussed above. the current resolution status, and actions remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues.

If you have any questions. please contact me at (301) 415 1362.

Sincerely.

Original Signed By Kristine M. Thomas. Project Manager Project Directorate IV 2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-482 )lSTRIBUT:08 L)ocket fi:ei cc: See next paga PUBLIC PDIV-2 Reading EGA1 WBateman KThomas EPeyton OGC ACRS BWetzel TMarsh PGwynn. Region IV WJohnson Region IV f

DOCUMENT NAME: WCGL9606.ltr 0FC PDly 2/LA PDIV-2/PM NAME KT N- EP M M

,DATE 11/ 2/97' 11/7 /97 _

0;FICIAL RECORD COPY 4

. Mr. Otto L. Maynard 4- November 12, 1997 i

cc:

Jay Silberg, Esq. Chief Operatin Officer Shaw. Pittman, Potts & Trowbridge Wolf Creek Nuc ear Operating Corporation -

2300 N Street, NW P. O. Box 411 Washington. 0.C. 20037 Burlington, Kansas 66839 ,

Regional Administrator, Region IV Supervisor Licensing U.S. Nuclear Regulatory Commission Wolf Creek Nuclear Operating Corporation 611 Ryan Pina Drive. Suite 1000 P.O. Box 411 l'

. Arlington, Texas 76011 Burlington, Kansas 66839 Senior Resident Inspector U.S. Nuclear Regulatory Comission i U.S. Nuclear Regulatory Comission Resident inspectors Office P, O. Box 311 8201 NRC Road Burlington, Kansas 66839 Steedman, Missouri 65077-1032 Chief Engineer <

Utilities Division Kansas Corporatior. Comission 1500 SW Arrowhead Road Topeka, Kansas 66604-4027 Office of the Governor 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 Vick L. Cooper, Chief Radiatico Control Program Kansas Department of Health and Environment ,

Bureau of Air t.nd Radiation Forbes Field BJilding 283 Topeka, Kansas 66620 t

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