WM 12-0003, Response to NRC Request for Additional Information Regarding 60-day Response to NRC Bulletin 2011-01,Mitigating Strategies
| ML12031A158 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/15/2012 |
| From: | Matthew Sunseri Wolf Creek |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| WM 12-0003 | |
| Download: ML12031A158 (13) | |
Text
WoLF CREEK NUCLEAR OPERATING CORPORATION Matthew W. Sunseri President and Chief Executive Officer January 15, 2012 WM 12-0003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Reference:
Letter dated November 30, 2011, from J. R. Hall, USNRC to M. W.
Sunseri, WCNOC, "Wolf Creek Generating Station - Request for Additional Information Regarding 60-day Response to NRC Bulletin 2011-01, 'Mitigating Strategies' (TAC NOS. ME6501)"
Subject:
Docket No. 50-482: Response to NRC Request for Additional Information Regarding 60-day Response to NRC Bulletin 2011-01, "Mitigating Strategies" Gentlemen:
The Reference issued a request for additional information (RAI) regarding Wolf Creek Nuclear Operating Corporation's (WCNOC) 60-day Response to NRC Bulletin 2011-01, "Mitigating Strategies." In accordance with 10 CFR 50.54(f), the attachment to this letter provides the response requested within 45 days of the date of the RAI.
This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4008, or Mr. Gautam Sen at (620) 364-4175.
Sincerely, Matthew W. Sunseri MWS/rlt Attachment cc: E. E. Collins (NRC), w/a J. R. Hall (NRC), w/a N. F. O'Keefe (NRC), w/a Senior Resident Inspector (NRC), w/a P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 tJ~p An Equal Opportunity Employer M/F/HCNET
WM 12-0003 Page 2 of 2 STATE OF KANSAS )
COUNTY OF COFFEY )
Matthew W. Sunseri, of lawful age, being first duly sworn upon oath says that he is President and Chief Executive Officer of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By Matthew W. Sunseri President and Chief Executive Officer SUBSCRIBED and sworn to before me this 15'day of son" ,2012.
Notary Public U Expiration Date /-//-/L
Attachment to WM 12-0003 Page 1 of 11 Response to Request for Additional Information Regarding 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies Reference 1 provided Wolf Creek Nuclear Operating Corporation's (WCNOC) 30-day response to NRC Bulletin 2011-01, "Mitigating Strategies." Reference 2 provided WCNOC's 60-day response to NRC Bulletin 2011-01. Reference 3 provided a request for additional information to support the NRC staff review of Reference 2. The specific NRC question is provided in italics.
Many of the items described below represent current station practices. Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, new or revised regulations, or other guidance in accordance with established processes.
- 1. Please describe in detail the maintenance or testing of monitor nozzles, spray nozzles, or similardevices to ensure that they will be functional when needed.
The bulletin requested that each licensee describe in detail the maintenance and testing on equipment procured to support the mitigating strategies to ensure that it will be functional when needed. In the context of the mitigating strategies,these devices are commonly used for firefighting, spent fuel pool spray strategies,and as a means to reduce the magnitude of fission product releases.
Response
Table 3.1, provided in response to question 3 in this document, identifies the support equipment that is dedicated to B.5.b mitigating strategies. Passive equipment, such as wrenches, flanges, and flow diffusers, require no periodic maintenance or testing. The ozzie monitors, spray nozzles, and gated wyes located on the B.5.b portable pump (fire truck) and the ventilation fans at the Fire Training Building are informally tested during fire brigade training addressing the use of B.5.b equipment. A formal periodic maintenance and testing program has not been established for B.5.b stored equipment that has an active function when operating. There is reasonable assurance that the equipment that is not periodically cycled during fire brigade training evolutions remains functional, because it is located in metal storage boxes, within the Auxiliary Building and Fuel Building. These boxes are dedicated for B.5.b equipment storage. The equipment in the boxes is only accessed for the performance of the quarterly inventory activity, which would identify observable equipment deficiencies. Additionally, in an effort to improve mitigating strategy response equipment availability during a B.5.b event, the equipment stored on the B.5.b portable pump is a duplicate of the equipment contained within the storage boxes in the Auxiliary Building and Fuel Building. Condition Report 00047383 has been initiated to develop a formal periodic maintenance and testing program for the B.5.b dedicated equipment identified in Table 1.1.
Attachment to WM 12-0003 Page 2 of 11 Table 1.1 - B.5.b Equipment Warranting Periodic Testing / Maintenance Equipment Test / Maintenance Activity Frequency Ozzie Monitors Inspect Annual Lubricate Functional flow test Spray Nozzles Inspect Annual Functional flow test Gated Wyes Open/close and inspect for Annual valve movement Gas Powered Ventilation Inspect Semi-annual Fans Check/change oil Operate Electric Powered Ventilation Inspect Semi-annual Fans Operate
- 2. Please describe in detail how the licensee ensures there is sufficient fuel for the pumping source when needed.
The bulletin requested that each licensee describe in detail the maintenance of equipment supporting the mitigatingstrategies to ensure that it will be functional when needed.
Response
The Wolf Creek Generating Station (WCGS) B.5.b portable pump is 1989 Pierce Lance fire truck rated for 2,000 gpm at 150 psi. It is provided with a rear mounted 65 gallon diesel fuel tank. Monthly inspection of the B.5.b portable pump ensures that the fuel gauge registers at least a 3/4 full level. WCNOC B.5.b response procedure EDMG T-01, "EDMG Tool Box,"
contains a precaution/limitation reminder that the B.5.b portable pump requires refueling after two hours of operation.
WCGS has a 10,000 gallon capacity in-ground tank, which stores highway grade diesel fuel.
The tank, located west of the Vehicle Maintenance Shop, has a usable capacity of 9,000 gallons. There is an AC powered submersible pump that supplies fuel to a dispenser located on a fuel service island north of the Vehicle Maintenance Shop. This dispenser is used for drive up-fuel service. Tank fuel level is monitored daily during the normal work week, based on fuel logs maintained at the fuel service island. Fuel is ordered when the tank level reaches approximately 2,000 gallons. Fuel for the tank is supplied by Hampel Fuel Oil distributors of Wichita, Kansas.
A 1976 Ford LN8000 fuel truck staged at the Vehicle Maintenance Shop is used to fill the fuel tank for the diesel fire pump, B.5.b portable pump, and other portable diesel equipment on the owner controlled property. It has a 650 gallon capacity bulk diesel fuel tank that is maintained at a level of at least 500 gallons. The fuel truck also has a 90 gallon capacity unleaded gasoline fuel tank. Diesel fuel is pumped off the truck via a gasoline engine driven centrifugal pump.
Attachment to WM 12-0003 Page 3 of 11 In the event the in-ground tank at the Vehicle Maintenance is not functional, the fuel truck can be driven to surrounding locations, (Burlington, LeRoy, Garnett, BETO Junction, etc.) to be filled with fuel. Also, Lewis Oil of Burlington, Kansas, LeRoy Coop of LeRoy, Kansas, and Lybarger Oil of Garnett, Kansas, have bulk trucks that can deliver fuel to Wolf Creek, if needed.
Five gallon fuel cans are located onsite at Vehicle Maintenance Shop that are available for use to manually fuel the B.5.b portable pump. A 12-volt DC powered electric pump is available to pump diesel fuel off the fuel truck if the gasoline engine driven centrifugal pump is not functional. Also available is a 12 volt DC powered emergency fuel pumping station in the tool room at the Vehicle Maintenance Shop. This is available as an alternate means for filling the fuel truck, fuel cans, or portable equipment with diesel fuel from the in-ground tank if necessary.
Alternate onsite diesel fuel storage sources include the two in-ground safety related storage tanks for the emergency diesel generators and an above-ground tank with approximately 469,000 gallon capacity that provides the fuel source for the auxiliary boiler.
The above discussion provides reasonable assurance that adequate diverse means have been established to ensure availability of a sufficient fuel source for the B.5.b portable pump.
Attachment to WM 12-0003 Page 4 of 11
- 3. Please identify the minimum inventory frequency for equipment needed for the mitigating strategies not specifically identified in response to the bulletin. Alternatively, please describe the inventory frequency for tools and instruments needed to support the mitigating strategies.
The bulletin requested that each licensee describe in detail the controls for ensuring equipment supporting the mitigating strategies will be available when needed. Tools and instruments are generally needed to implement the mitigating strategies, but these items were not clearly included in the licensee's response to the bulletin.
Response
The equipment identified in Table 3.1 is dedicated to B.5.b mitigating strategy response.
The equipment is inventoried, per WCNOC procedure Al 10-001, "Fire Brigade Equipment Inventory Maintenance and Cleaning," as identified in Table 3.1.
Table 3.1 - B.5.b Equipment Qty. Description Location Inventory Frequency 3 3-inch fire hose equipped with 2.5-inch fire Fuel Building 2047'- Quarterly hose thread couplings, orange, 50-foot Storage Box length (nominal) 1 4-inch fire hose equipped with Storz Fuel Building 2047' - Quarterly couplings, yellow, 100-foot length Storage Box (nominal) 1 Ozzie water monitor (style 911), equipped Fuel Building 2047' - Quarterly with one 2.5-inch female fire hose thread Storage Box inlet), and style 4827 fog nozzle 1 Flow diffuser, cone shaped, galvanized, Fuel Building 2047' - Quarterly equipped with one 2.5-inch female fire Storage Box hose thread inlet 1 Gated wye equipped with one 4-inch Storz Fuel Building 2047' - Quarterly inlet & two 2.5-inch inch male fire hose Storage Box thread outlets 2 Nylon strap, made from black rescue Fuel Building 2047' - Quarterly webbing, and equipped with carabiner Storage Box 2 Spanner wrench, for use on threaded fire Fuel Building 2047' - Quarterly hose couplings Storage Box 2 Wood wedge Fuel Building 2047' - Quarterly Storage Box 3 3-inch fire hose equipped with 2.5-inch fire Auxiliary Building 2047' Quarterly hose thread couplings, orange, 50-foot South End - Storage Box length (nominal)
Attachment to WM 12-0003 Page 5 of 11 Qty. Description.. Location Inventory Frequency 1 4-inch fire hose equipped with Storz Auxiliary Building 2047' Quarterly couplings, yellow, 100-foot length South End - Storage Box (nominal) 1 Ozzie water monitor (style 911), equipped Auxiliary Building 2047' Quarterly with one 2.5-inch female fire hose thread South End - Storage Box inlet), and style 4827 fog nozzle 1 Flow diffuser, cone shaped, galvanized, Auxiliary Building 2047' Quarterly equipped with one 2.5-inch female fire South End - Storage Box hose thread inlet 1 Gated wye equipped with one 4-inch Storz Auxiliary Building 2047' Quarterly inlet & two 2.5-inch male fire hose thread South End - Storage Box outlets 1 Spectacle flange, stainless steel, with Auxiliary Building 2047' Quarterly handle (replaces flow orifice ENFOO001) South End - Storage Box 2 Nylon strap, made from black rescue Auxiliary Building 2047' Quarterly webbing, and equipped with carabineer South End - Storage Box 2 Spanner wrench, for use on threaded fire Auxiliary Building 2047' Quarterly hose couplings South End - Storage Box 2 Wood wedge Auxiliary Building 2047' Quarterly South End - Storage Box 6 3-inch fire hose equipped with 2.5-inch fire Auxiliary Building 2047' Quarterly hose thread couplings, orange, 50-foot North End - Storage Box length (nominal) 2 3-inch bolted pipe flange to 2.5-inch Auxiliary Building 2047' Quarterly female fire hose connection adapter with North End - Storage Box gasket 1 4-inch bolted pipe flange to 2.5-inch Auxiliary Building 2047' Quarterly female fire hose connection adapter with North End - Storage Box gasket 2 Nylon strap, made from black rescue Auxiliary Building 2047' Quarterly webbing, and equipped with carabineer North End - Storage Box 2 Spanner wrench, for use on threaded fire Auxiliary Building 2047' Quarterly hose couplings North End - Storage Box 2 Wood wedge Auxiliary Building 2047' Quarterly North End - Storage Box 4 12-inch adjustable wrenches (Crescent Auxiliary Building 2047' Quarterly type) North End - Storage Box 2 1 1A inch combination (box/open end) Auxiliary Building 2047' Quarterly wrenches North End - Storage Box
Attachment to WM 12-0003 Page 6 of 11 Oty. Description Location Inventory Frequency 2 Gas powered ventilators Fire Training Building Quarterly 2 Electric powered ventilators Fire Training Building Quarterly 20 Bunker coats (assorted sizes)* Fire Training Building Quarterly 20 Bunker pants (assorted sizes)* Fire Training Building Quarterly 20 Pairs of fire boots (assorted sizes)* Fire Training Building Quarterly 20 Fire gloves (assorted sizes)* Fire Training Building Quarterly 20 Fire helmets* Fire Training Building Quarterly 20 Fire hoods* Fire Training Building Quarterly 2 2.5 inch double male fire hose thread B.5.b Portable Pump (Fire Quarterly adapter Truck) 2 2.5 inch double swivel female fire hose B.5.b Portable Pump (Fire Quarterly thread adapter Truck) 2 3-inch bolted pipe flange to 2.5-inch B.5.b Portable Pump (Fire Quarterly female fire hose connection adapter, with Truck) gasket 1 3-inch female pipe thread to 2.5-inch B.5.b Portable Pump (Fire Quarterly female fire hose connection adapter Truck) 1 4-inch bolted pipe flange to 2.5-inch B.5.b Portable Pump (Fire Quarterly female fire hose connection adapter, with Truck) gasket 1 4-inch bolted pipe flange to 4-inch Storz B.5.b Portable Pump (Fire Quarterly fire hose connection adapter, with gasket Truck) 1 Spectacle flange, stainless steel, with B.5.b Portable Pump (Fire Quarterly handle (Replaces Flow Orifice ENFOO001) Truck) 1 4-inch female hydrant steamer connection B.5.b Portable Pump (Fire Quarterly thread to 4-inch Storz fire hose adapter Truck) 1 4.5-inch female hydrant steamer B.5.b Portable Pump (Fire Quarterly connection thread to 4-inch Storz fire hose Truck) adapter 2 Ozzie water monitor (style 911), equipped B.5.b Portable Pump (Fire Quarterly with one 2.5-inch female fire hose thread Truck) inlet), and style 4827 fog nozzle 2 Flow diffuser, cone shaped, galvanized, B.5.b Portable Pump (Fire Quarterly equipped with one 2.5-inch female fire Truck) hose thread inlet
Attachment to WM 12-0003 Page 7 of 11 Qty. Description Location Inventory Frequency 1 Floating strainer equipped with 6-inch B.5.b Portable Pump (Fire Quarterly threaded inlet Truck) 2 Hard suction hose 10-feet in length B.5.b Portable Pump (Fire Quarterly (nominal), and equipped with 6-inch thread Truck) couplings 1 Gated manifold equipped with one 4-inch B.5.b Portable Pump (Fire Quarterly Storz inlet & three 2.5-inch male fire hose Truck) thread outlets 100 .75-inch high pressure steam hose, with B.5.b Portable Pump (Fire Quarterly feet universal pipe flange and weighted end. Truck)
One 50-foot section (nominal) in truck compartment C1, and the other 50-foot section (nominal) in truck compartment S1 600 3-inch fire hose equipped with 2.5-inch fire B.5.b Portable Pump (Fire Quarterly feet hose thread couplings, orange, 50-foot Truck) lengths (nominal), pre-connected in hose bed 1600 4-inch fire hose equipped with Storz B.5.b Portable Pump (Fire Quarterly feet couplings, yellow, 100-foot lengths Truck)
(nominal), pre-connected in hose bed 4 Adjustable open end wrenches (Crescent B.5.b Portable Pump (Fire Quarterly type) Truck) 2 1 1/4 inch combination (box/open end) B.5.b Portable Pump (Fire Quarterly wrenches Truck) 1 24 inch pipe wrench B.5.b Portable Pump (Fire Quarterly Truck) 1 36 inch pipe wrench B.5.b Portable Pump (Fire Quarterly Truck) 1 Combination wrench set B.5.b Portable Pump (Fire Quarterly Truck) 4 Sling with carabiner B.5.b Portable Pump (Fire Quarterly Truck) 1 Bag containing door chocks B.5.b Portable Pump (Fire Quarterly Truck)
N/A Misc. length of rope B.5.b Portable Pump (Fire Quarterly Truck) 1 Procedure Al 10-106, Operation off the B.5.b Portable Pump (Fire Quarterly WCGS Fire Truck Truck) 1 Procedure AP 10-106, Fire Preplans B.5.b Portable Pump (Fire Quarterly Truck)
Attachment to WM 12-0003 Page 8 of 11 Qty. Description Location Inventory Frequency 2 Procedure EDMG-TO1, EDMG Tool Box B.5.b Portable Pump (Fire Quarterly Truck) 2 Procedure EDMG-001, Extensive Damage B.5.b Portable Pump (Fire Quarterly Mitigation Guidelines Truck) 2 Form AIF 10-001-03, WCGS Fire Truck B.5.b Portable Pump (Fire Quarterly Inventory Sheet Truck) 2 Form AIF 10-001-05, EDMG-TO1 B.5.b Portable Pump (Fire Quarterly Equipment Storage Box/Other B.5.b Truck)
Equipment Inventory 4 SCBA with mask B.5.b Portable Pump (Fire Monthly Truck) 20* SCBA with mask Fire Training Building Monthly
- Denotes a typical quantity on hand, from fire training stock.
The equipment identified in Table 3.2 supports fire brigade response. However, it can be used for B.5.b response, as necessary. The equipment is inventoried as identified in Table 3.2.
Table 3.2 - Fire Brigade Equipment oty. Description Location Inventory Frequency 5 Helmets Dress-Out Lockers - 2000' Quarterly Communications Corridor 5 Flashlights Dress-Out Lockers - 2000' Quarterly Communications Corridor 5 Spanner hose wrench Dress-Out Lockers - 2000' Quarterly Communications Corridor 1 Procedure AP 10-106, Fire Preplans Dress-Out Lockers - 2000' Quarterly Communications Corridor 5 SCBA Mask Dress-Out Lockers - 2000' Quarterly Communications Corridor 5 Radios Gray Cabinet Near Dress-Out Quarterly Lockers 2 Hand lanterns Gray Cabinet Near Dress-Out Quarterly Lockers 1 Maintenance jack head set Gray Cabinet Near Dress-Out Quarterly Lockers
Attachment to WM 12-0003 Page 9 of 11 oty. Description Location Inventory Frequency 5 Spare SCBA air bottles on hand cart Communications Corridor 2000' Quarterly Stair CC-1 1 Two wheel dolly Attack Pack Communications Corridor 2000' Quarterly Stair CC-i of 1-1/2 inch hose Two 50 foot lengths Two pistol grip nozzles One wye, 2-1/2 to two 1-1/2 inch 1 Pry bar (3 foot) Communications Corridor 2000' Quarterly Stair CC-1 2 50 foot sections of 2-1/2 inch hose Communications Corridor 2000' Quarterly Stair CC-1 1 Tool box Communications Corridor 2000' Quarterly Stair CC-1 and Fire Brigade Equipment Locker 1 2-1/2 inch adjustable nozzle Communications Corridor 2000' Quarterly Stair CC-1 1 Set stacked tips for deluge set Communications Corridor 2000' Quarterly Stair CC-1 2 16 inch Electric ventilation fans Communications Corridor 2000' Quarterly Stair CC-1 3 Duct segments for ventilation fans Communications Corridor 2000' Quarterly Stair CC-1 3 Ventilation Fan Duct Adaptors Communications Corridor 2000' Quarterly Stair CC-1 1 Extension power cord on reel Communications Corridor 2000' Quarterly Stair CC-1 1 Deluge set with "Black Widow" tip Communications Corridor 2000' Quarterly Stair CC-1 1 Dolly (CTMT standpipe outage use: 1- Auxiliary Building 1974' Fire Quarterly 1/2 and 2-1/2 inch hose, wye, 1-1/2 Brigade Equipment Locker inch double female connection, and nozzles) 1 Dolly: Auxiliary Building 1974' Fire Quarterly
" One Attack Pack: 1-1/2 inch hose, Brigade Equipment Locker wye, and nozzles
" Tool box
" Bolt cutters
" Pick headed ax
" Crow bar 7 Fire Brigade SCBA with mask Communications Corridor 2000' Monthly Stair CC-1
Attachment to WM 12-0003 Page 10 of 11
- 4. Please describe in detail the semiannualmaintenance activities for the B.5.b portablepump.
The bulletin requested that each licensee describe in detail the maintenance of equipment supporting the mitigating strategies to ensure that it will be functional when needed. The NRC determined that the description of the semiannual maintenance performed on the B.5.b portable pump is not detailed since it only states that "generalmaintenance activities" are performed. The NRC staff notes that the licensee's response states a condition report was generated to consider clarifying this maintenance.
Response
Periodic preventive maintenance (PM) for the B.5.b portable pump (fire truck) is performed by WCNOC Vehicle Maintenance Shop personnel. This activity is triggered by a repetitive PM work order. If degradation or failures are found, action is taken to resolve the issue.
The semi-annual PM activity addresses the following attributes:
Engine Oil and Filter - Change Transmission Fluid - Check/Change Lube Points / Grease Fittings Differential Fluid - Check/Change Frame / Drive Train / U-Joints - Check/Lube Transfer Case Fluid - Check/Change Steering - Check King Pins / Ball Joints - Check Clutch - Check Fuel Filter - Check/Change Tires / Wheels / Pressure / Spare - Check/Rotate Wheel Bearings / Check Service Brakes / Brake Fluid Level / Air Pressure - Check/Adjust Parking / Emergency Brakes - Condition/Operation Springs / Shocks - Check Power Steering Fluid - Check Battery - Check/Clean/Condition Air Filter - Check/Change Breather - Check/Change Belts - Check Hoses - Check Coolant - Check/Change/Condition Leaks - Air/Coolant/Oil - Check
Attachment to WM 12-0003 Page 11 of 11 Cab/Body/Enclosure - Check Glass - Check Mirrors - Check Windshield Wipers/Washer - Check Horn - Check Seatbelts - Check Heater / Defroster - Check Head Lamps - Check Tail Lamps/Tag Light - Check Turn Signals - Check Hazard Flasher - Check Stop Lamps - Check Clearance Lamps - Check Dome/Cab Lamp - Check Spot Lamp - Check
References:
- 1. WCNOC letter WO 11-0031 "30-day Response to NRC Bulletin 2011-01, "Mitigating Strategies"," June 9, 2011
- 2. WCNOC letter WO 11-0055 "60-day Response to NRC Bulletin 2011-01, "Mitigating Strategies"," July 11, 2011
- 3. Letter dated November 30, 2011, from J. R. Hall, USNRC to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Request for Additional Information Regarding 60-day Response to NRC Bulletin 2011-01, "Mitigating Strategies" (TAC NOS. ME6501)"