ML20217N494

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Requests Approval of Relief Requests Submitted by Supplemental Info Re ISI Relief Requests I1R-46 & I2R-21
ML20217N494
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 08/20/1997
From: Muench R
WOLF CREEK NUCLEAR OPERATING CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ET-97-0092, ET-97-92, NUDOCS 9708260201
Download: ML20217N494 (2)


Text

.

s W4%LF CREEK NUCLEAR OPERATING CORPORATION n

,o 3 %,n3 Vice President Engineenng August 20, 1997 ET 97-0092 U. S, !!uclear Regulatory Commission ATTN:

Document Control Desk

!! ail Station F1-137 Washington, D. C.

20555

Reference:

WCNOC Letter ET 97-0031, from R. A. Muench, WCMOC, to U.S. Nuclear Regulatory Commission

Subject:

Docket No. 50-482:

Supplemental Information Related to ISI delief Requests IIR-46 through I1R-49 and I2R-21 Gentlemen:

On June 12, 1997, NRC Project Manager, J.

C.

Stone, called the Wolf Creek Nuclear Operating Corporation (WCNOC) Supervisor Licensing, T. M.

Damashek, to discuss submittal of Inservice Inspection (ISI) Relief Requests IIR-46 through IIR-49 and I2R-21.

These relief requests were transmitted by the Reference.

The. relief requests, with the exception of I2R-21, were the subject of ISI limited examinations for the First 10-Year ISI Interval.

The telephone call concerned the reference to the correct subparagraph of 10CFR 50.55a, " Codes and Standards."

The relief requests were submitted pursuant to 10CER50. 55a (g) (5) (iii), on the basis that conformance with the code requirements is imoractical.

Although the basis for impracticality was correct, 10CFR50.55a (g) s5) (iv) provides additional guidance on submittal of relief requests when the 10 year ISI interval has been completed.

10CFR50. 55a (g) ( 5) (iv) requires that when the impracticality is not the subject of a subsequent 10-year ISI interval program plan submittal, then the relief requests must be submitted and the basis for the determination of impracticality be demonstrated to the satisfaction of the Commission.

This shall occur not later than 12 months after the expiration of the initial 120-month (10-year) period of operation from the start of facility commercial operation.

The initial 10-year period of operation was completed on September 2,

1995; therefore, the submittal of these relief requests should have been performed prior tc September 1996.

The interval was extended as allowed by 10CFR50.55a and ASME Section XI to include RF8 activities which was completed on April 7, 1997.

.However, the Reference did not meet the requirements because it was dated May 23, 1997.

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9708260201 970820 PDR ADOCK 05000482 G

PDR Ill.l!ll.l!ll.lll:

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P.O. Box 411 i Burlington, KS 66839 / Phone: (316; 6o4-8831 An Equa Opporturnty Ernetoyer M F HCeVET l

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e Letter ET 97-0092 Page 2 of 2 This Arcue has been evaluated by the WCNOC corrective action prtgram.

The evaluation concluded that 101 Relief Requests 11R-46 through 11R-49 should have been submitted in.ccordance with 10 CFR 50. LLa (g) (L) (iii) and 10 CFR

50. 55a (g) ( 5) (i v). The evaluation also concluded that this error occurred because responsible personnel were not cognizant of the requirements of 10 CFR 50.55a (g) (L) (iv).

In addition, the evaluation concluded that procedural guidance to alert personnel to the requirement is not included in Procedure 1.r 29A-002, " Inservice Inspection Program."

Procedure AP 29A-002 will be revreed to include requirement s 10 CFR 50.55a (g) (L) (iv) by October 2, 1997 Tht technical basis of the Reference remains unchanged.

Therefore, WCNOC continues to request approval of the relief requests submitted by the Reference.

If you have any questions concerning this matter, please cont act me at (316) 304-8831, extension 4034, or Mr.

Richard D.

Flannigan, at extension 4 BOO.

Very truly yours, Richa d A. Muench PAM/jad cc:

W. D. Johnson (NRC)

E. W. Merschoff (NRC)

J.

F.

Ringwald (NRC)

J. C.

Stone (NRC)

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