ML25267A244
| ML25267A244 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/24/2025 |
| From: | Bayer R Wolf Creek |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 001183 | |
| Download: ML25267A244 (1) | |
Text
P.O. Box 411 l Burlington, KS 66839 l 620-364-8831 Robert J. Bayer Vice President Engineering September 24, 2025 001183 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Reference:
Letter 000873, dated May 8, 2025, from M.T. Boyce, WCNOC, to USNRC, Docket No. 50-482: Proposed Alternative to Use American Society of Mechanical Engineers (ASME) Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 SystemsSection XI, Division 1, (ADAMS ML25128A304)
Subject:
Docket No. 50-482: Supplement to Proposed Alternative to Use American Society of Mechanical Engineers (ASME) Code Case N-752 Commissioners and Staff:
On May 8, 2025, by the above Reference pursuant to 10 CFR 50.55a(z)(1), Wolf Creek Nuclear Operating Corporation (WCNOC) submitted a relief request to the U.S. Nuclear Regulatory Commission (NRC) seeking approval to use American Society of Mechanical Engineers (ASME)
During review of the referenced relief request, the NRC Office of Nuclear Reactor Regulation (NRR) contacted WCNOC noting the relief request proposed using an Integrated Decision-making Panel (IDP) based on 10 CFR 50.69.
Repeated from Section D of Attachment to the above Reference, the following statement was included.
If there is a significant impact on the PRA model, the [structure, system, or component]
SSC categorization will be re-evaluated and presented to the Integrated Decision-making Panel (IDP). This approach is consistent with the feedback and adjustment process of 10 CFR 50.69(e).
As communicated by NRR, the use of the 10 CFR 50.69 IDP is acceptable; however, it is more rigorous than the categorization process required by ASME Code Case N-752.
To prevent limiting the station to the use of the 50.69 IDP, WCNOC requests that the relief request be modified to follow the categorization process outlined in Section 1300 Owners Responsibility of Code Case N-752 for 1310, Determination of Category and 1320, Required Disciplines.
001183 Page 2 of 2 For clarity, 1320 from N-752 states the following:
The Owner shall provide personnel to perform the risk-informed categorization evaluation, review, and documentation. Personnel with expertise in the following disciplines shall be included: (a) probabilistic risk assessment (PRA), (b) plant operations, (c) system design, (d) safety or accident analysis. Personnel may be experts in more than one discipline, but are not required to be experts in all disciplines.
In summary, WCNOC intends to follow the categorization process outlined in ASME Code Case N-752 but may choose to apply the more rigorous 50.69 IDP process where appropriate.
This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4015, or Dustin Hamman at (620) 364-4204.
Sincerely, Robert J. Bayer RJB/nwl cc:
A. N. Agrawal (NRC)
S. S. Lee (NRC)
J. D. Monninger (NRC)
Senior Resident Inspector (NRC)