ML20212N299

Forwards Request for Addl Info Re Util 851211 & 13 Submittals on First 10-yr Internal Inservice Insp Program Plan

ML20212N299
Person / Time
Site:	Wolf Creek
Issue date:	08/27/1986
From:	Oconnor P Office of Nuclear Reactor Regulation
To:	Koester G KANSAS GAS & ELECTRIC CO.
References
NUDOCS 8608280174
Download: ML20212N299 (10)

Text

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Docket No. 50-482 2 7 AUG 1986 Mr. Glenn L. koester Vice President - Nuclear Kansas Gas & Electric Company 201 North Market Street Wichita, Kansas 63166

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN FOR WOLF CREEK GENERATING STATION l

Thc staff is continuing its review of your submittals dated December 11, 1985 ,

and supplements thereto dated December 11 and 12,1985. To permit us to '

continue our review on our current schedule; we require the information requested in Enclosure 1 to this letter be provided.

• Please provide'the requested information within 45 days of your receipt of this letter.

Sincerely, 1 Paul W. O'Connor, Project Manager PWR Project Directorate #4

• Division of PWR Licensing-A

Enclosure:

As stated cc: See next page

, DISTRIBUTION:

poctet:r11e.' '

Local PDR NRC PDR PWR#4 Reading BJYoungblood  :

P0'Connor MDuncan  !

OGC Edordan  ;

BGrimes '

JPartlow ,

I NThompson ACRS(10) hl  ;

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PWR#4/DP R-A PWR#4/ PWR-A P0'Connor/ rad BJYoungblood '

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8608280174 860827 PDR ADOCK 05000482 O PDR

Mr. Glenn L. Koester Wolf Creek Generating Station Kansas Gas and Electric Company Unit No. I cc:

Mr. Nicholas A. Petrick C. Edward Peterson, Esq.

Executive Director, SNUPPS Legal Division ,

5 Choke Cherry Road Kansas Corporation Commission Rockville, Maryland 20850 State Office Building, Fourth Floor Topeka, Kansas 66612 Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge' Regional Administrator, Region IV 1800 M Street, NW U.S. Nuclear Regulatory Commission Washington, D.C. 20036 Office of Executive Director for Operations Mr. Donald T. McPhee 611 Ryan Plaza Drive, Suite 1000 Vice President - Production Arlington, Texas 76011 Kansas City Power & Light Company

. 1330 Baltimore Avenue Mr. Allan Mee Kansas City, Missouri 64141 Project Coordinator Kansas Electric Power Cooperative,Inc.

Chris R. Rogers, P.E. P. O. Box 4877 Manager, Electric Department Gage Center Station Public Service Conmission Topeka, Kansas 66604 P. O. Box 360 Jefferson City, Missouri 65102 Resident Inspector / Wolf Creek NPS

, c/o U.S. Nuclear Regulatory Commission Regional Administrator, Region III P. O. Box 311 U.S. Nuclear Regulatory Commission Burlington, Kansas 66893 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Robert M. Fillmore State Coporation Commission Brian P. Cassidy, Regional Counsel State of Kansas Federal Dnergency Management Agency Fourth Floor, State Office Building Region I Topeka, Kansas 66612 J. W. McCormack P0CH Boston, Massachusetts 02109 Senior Resident Inspector / Wolf Creek NPS c/o U.S. Nuclear Regulatory Commission Terri Sculley, Director P. O. Box 311 Special Projects Division Burlington, Kanses 66839 Kansas Corporation Commission State Office Building, Fourth Floor Topeka, Kansas 66612 Mr. Gerald Allen Public Health Physicist '

Bureau of Air Quality & Radiation Control Division of Environment Kansas Department of Health and Environment Forbes Field Building 321 Topeka, Kansas 66620

ENCLOSURE 1 KANSAS GAS AND ELECTRIC CO.

- WOLF CREEK GENERATING STATION DOCKET NUMBER 50-482 ENGINEERING BRANCH DIVISION OF PWR LICENSING - A Request for Additional Information - First 10-Year Interval Inservice i Inspection Program

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1. Scope / Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) which are classified as ASME Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the l extent practical within the limitations of design, geometry, and l

! materials of construction of the components. This section of the l regulations also requires that inservice examinations of components

.and system pressure tests conducted during the initial 120-month inspection interval shall comply with the requirements in the latest -

edition and addenda of the Code incorporated by reference in ,

i 10 CFR 50.55a(b) on the date 12 months prior to the date of issuance ,

of the operating license, subject to the limitations and modifications t listed therein. The components (including supports) may meet i requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the l limitations and modifications listed th3 rein. Based on the Operating License date of March 11, 1985, the Licensee has prepared the ISI .

! Program to meet the requirements of the 1980 Edition, Winter 1981  !

I Addenda (80W81) of ASME Code Section XI except that the extent and frequency of examination for Code Class 2 piping has been determined by the 1974 Edition through Summer 1975 Addenda (74S75).  ;

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As required by 10 CFR 50.55a(g)(5), if the licensee determines that l certain code exarination requirements are impractical and relief is requested, the licensee shall submit information to the staff to -

support that determination. l 1 r The staff has reviewed the available information in the Wolf Creek [

First 10-Year Interval Inservice Inspection Program Plan submitted  ;

l December 11, 1985 and the requests for relief from ASME Code i

. Section XI requirements which the Licensee has determined to be {

impractical to perform at Wolf Creek submitted December 11, 1985 and  !

! December 13, 1985.  !

2. Staff Evaluation [

Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the [

review of the Inservice Inspection Program Plan: '

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A. Paragraph 10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 4

piping welds in the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems shall be examined. These systems should not be completely exempted from inservice volumetric examination based on Section XI exclusion criteria contained in IWC-1220. The ISI Program Plan for the Containment Cooling System (NES document No. 83A1703) should be revised to include volumetric examinathn of a representative sample of welds..

B. Paragraph IWC-1220(d), of the ASME Code Section XI 1974 Edition, i

Sumer 1975 Addenda, states that component connections, piping i and associated valves, and vessels (and their sJpports), that are 4 in, nominal pipe size and smaller may be exempted from the ,

i examination requirements of IWC-2520. In the ISI Program Plan for the Chemical and Volume Control System (NES document No. 83A1698), piping 442-BCB-12 and 444-BCB-10 arc listed as exempt per IWC-1220(d) and treated as vessels with 3 in.

- connections. Section 2.1, of the ISI Program Plan, states"

" Letdown delay lines 442-BCB-12 and 444-BCB-10, with inlet and outlet lines of 3 in and 1 in. NPS, respectively, are considered exempt because the failure of the 10 in and 12 in. lines are of no greater consequences than the failure of the 1 in and 3 in.

lines, which are exempt per Section XI." The Licensee may not arbitrarily rename a pipe as a vessel. If the Licensee has i determined the ASME Code requirements for examination of these two lines to be impractical to perform, a request for relief from '

the ASME Code Section XI requirements should be submitted for staff review.

C. ASME Code Section XI paragraph IWF-2510, " Supports Selected for Examination", states that component supports selected for examination shall be the supports of those components that are required to be examined under IWB, IWC, IWD, and IWE during the first inspection interval, and for multiple components within a system of similar design, function, and service, the supports of only one of the multiple components are required to be examined.  :

i Relief Request M references a statistical sampling plan (located '

in the ISI Program Plan for Component Supports (NES document lr No. 83A1714'Rev.3)) for the selection of piping support r~

assemblies for examination as the alternative to the Code requirements. For the proposed alternative to the requirements of ASME Section XI, Subsection IWF, demonstrate that: (1) the

selection of ' piping support assemblies for examination meets or exceeds the Code requirements, or (2) compliance with the Code ,

requirements would result in hardship or unusual difficulties  !

without a compensating increase in the level of quality and l safety, as required by 10 CFR 50.55a(a)(3). l D. Verify that there are no additional relief requests, other than j those submitted December 11, 1985 and December 13, 1985. If  :

additional relief requests are required, the Licensee should l submit them for staff review. When preparing requests for ]

relief, the staff suggests that the Licensee follow the attached j Appendix A, " Guidance for Preparing Requests for Relief from l

Certain Code Requirements Pursuant to 10 CFR 50.55a(a)(3)". ,

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The Licensee should provide the above requested information and/or clarifications as soon as possible so that the review of the Inservice Inspection Program Plan can be completed.

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APPENDIX A GUIDANCE FOR PREPARING REQUESTS FOR RELIEF FROM CERTAIN CODE REQUIREMENTS PURSUANT TO 10 CFR 50.55a(a)(3)

A. Description of Requests for Relief The guidance in this enclosure is intended to illustrate the type and extent of information that is necessary for " request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code. The preservice/ inservice inspection program should identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitation of design, geometry, radiation considerations or materials of construction of the components. The request for relief should provide the information requested in the following section of this appendix for the inspections and pressure tests identified above.

- 8. Request for Relief From Certain Inspection and Testing Requirements Many requests for relief from testing requirements submitted by licensees have not been supported by ade:;uate descriptive and detailed technical information. This detailed information is necessary to: (1) document the impracticality of the ASME Code requirements within the limitations of design, geometry and materials of construction of components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety.

Relief request submitted with a justification such as " impractical",

" inaccessible", or any other categorical basis, require additional information to permit an evaluation of that relief request. The objective of the guidance provided in' this section is to illustrate the extent of the information that is required to make a proper evaluation and to adequately document the basis for granting the relief in the Safety Evaluation Report. Subsequent requests for sdditional information and delays in completing the review can be considerably reduced if this information is provided initially in the licensee's submittal.

For each relief request submitted, the following information should be included:

1. An identification of the component (s) and the examination  ;

requirement for which relief is requested.  ;

2. The number of items associated with the requested relief.

3. The ASME Code class.

4. An identification of the specific ASME Code requirement that has been determined to be impractical. t

5. The information to support the determination that the requirement is impractical; i.e., state and explain the basis for requesting 4

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l relief. If the Code required examination cannot be performed I because of a limitation or obstruction, describe or provide drawings  !

showing the specific limitation or obstruction, and provide an estimate of the percertage of the Code required examination that can be completed on the individual components requiring relief.

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6. An identification of the alternative examinations that are proposed:

, (a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance with the requirements l

of Section XI.

i 7. A description of the ASME Code Section III fabrication examinations that were completed and documented during construction for the

- specific components listed in the relief requests.

8. A description and justification of any changes expected in the overall level of plant safety by performing the proposed alternative examination in lieu of the examination required by Section XI. If

. it is not possible to perform alternate examinations, discuss the  :

) impact on the overall level of plant quality and safety.

For inservice inspection, provide the following additional information j regarding the inspection frequency:

1. State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination.) ,

2. State when the proposed alternative examinations will be implemented and performed.

3. State the time period for which the requested relief is needed.

Technical justification or data must be submitted to support the relief i request. Opinions without substantiation that a change will not affect

! the quality level are unsatisfactory. If the relief is requested for

inaccessibility, a detailed description or drawing which depicts the j inaccessibility must accompany the request. A relief request is not required for tests prescribed in Section XI that do not apply to your facility. A statement of "N/ A" (not applicable) or "none" will suffice.

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C. . Request for Relief for Radiation Considerations i

l Exposures of test personnal to radiation to accomplish tne examinations i prescribed in Section XI of the ASME Code can be an important factor in i determining whether, or under what conditions, an examination must be performed. A request for relief must be submitted by the licensee in the 4 manner described above for inaccessibility and must be subsequently I approved by the NRC staff.

Some of the radiation considerations will only be known at the time of i '

the test. However, from experience at operating facilities, the licensee j generally is aware of those areas where relief will be necessary and should submit as a minimum, the following information with the request t for relief:

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1. The total estimated man-rem exposure involved in-the examination.

2. The radiation levels at the test area.

3. Flushing or shielding capabilities which might reduce radiation levels.

4. A proposal for alternate inspection techniques.

5. A discussion of the considerations involved in remote inspections.

6. Similar welds in redundant systems or similar welds in the same systems which can be inspected.

7. The results of preservice inspection and any inservice results for the welds for which the relief is being requested.

8. A discussion of the failure consequences of the weld which would not ,

receive the Code required examination.

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Docket No. 50-482 2 7 AUG 1986 Mr. Glenn L. Koester Vice President - Nuclear Kansas Gas & Electric Company 201 North Market Street Wichita, Kansas 63166

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE FIRST TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN FOR WOLF CREEK GENERATING STATION The staff is continuing its review of your submittals dated December 11, 1985 and supplements thereto dated December 11 and 13, 1985. To permit us to continue our review on our current schedule; we require the infonnation requested in Enclosure 1 to this letter be provided.

Please provide the recuested infonnation within 45 days of your receipt of this letter.

Sincerely, I

Paul W. O'Connor, Project Manager PWR Project Directorate #4 Division of PWR Licensing-A

Enclosure:

As stated cc: See next page DISTRIBUTION:

Docket File Local PDR NRC PDR PWR#4 Reading BJYoungblood P0'Connor MDuncan 0GC EJordan BGrimes JPartlow NThom ACRS(pson0) [

PWR#4/DP R-A PWR#4/DPWR-A P0'Connor/ rad BJYoungblood 08/; 6 08p86

! Mr. Glenn L. Koester Wolf Creek Generating Station ,

Kansas Gas and Electric Company Unit No. I c:

3 Mr. Nicholas A. Petrick C. Edward Peterson, Esq.

Executive Director, SNUPPS Legal Division 5 Choke Cherry Road Kansas Corporation Comission Rockville, Maryland 20850 State Office Building, Fourth Floor Topeka, Kat.sas 66612 4

Jay Silberg, Esq.

2 Shaw, Pittman, Potts & Trowbridge Regional Administrator, Region IV 1800 M Street, NW U.S. Nuclear Regulatory Comission Washington, D.C. 20036 Office of Executive Director for Operations Mr. Donald T. McPhee 611 Ryan Plaza Drive, Suite 1000 Vice President - Production Arlington, Texas 76011 Kansas City Power & Light Company i

. 1330 Baltimore Avenue Mr. Allan Mee Kansas City, Missouri 64141 Project Coordinator Kansas Electric Power Cooperative,Inc.

, Chris R. Rogers, P.E. P. '0 Box 4877 4 Manager, Electric Department Gage Center Station i Public Service Comission Topeka, Kansas 66604 P. O. Box 360 Jefferson City, Missouri 65102 Resident Inspector / Wolf Creek NPS c/o U.S. Nuclear Regulatory Comission Regional Administrator, Region III P. O. Box 311 U.S. Nuclear Regulatory Comission Burlington, Kansas 66893 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Robert M. Fillmore State Coporation Comission

Brian P. Cassidy, Regional Counsel State of Kansas I Federal Emergency Management Agency Fourth Floor. State Office Building Region I .

Topeka, Kansas 66612 J. W. McCormack POCH Boston, Massachusetts 02109 Senior Resident Inspector / Wolf Creek NPS c/o U.S. Nuclear Regulatory Comission Terri Sculley, Director P. O. Box 311 Special Projects Division Burlington, Kansas 66839 Kansas Corporation Comission State Office Building, Fourth Floor i

Topeka, Kansas 66612 Mr. Gerald Allen l

) Public Health Physicist Bureau of Air Quality & Radiation Control Division of Environment Kansas Department of Health i

and Environment '

Forbes Field Building 321  ;

Topeka, Kansas 66620 l

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