ML072950027

RAI, Response to Generic Letter 2007-01

ML072950027
Person / Time
Site:	Wolf Creek
Issue date:	10/25/2007
From:	Donohew J N NRC/NRR/ADRO/DORL/LPLIV
To:	Muench R A Wolf Creek
Donohew J N, NRR/DORL/LP4, 415-1307
References
GL-07-001, TAC MD4397
Download: ML072950027 (4)

Text

October 25, 2007

Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION ON THE RESPONSE TO GENERIC LETTER 2007-01 (TAC NO. MD4397)

Dear Mr. Muench:

On February 7, 2007, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients." In GL 2007-01, the NRC requested information from the licensees of operating nuclear power plants on the history of failures at their plants of inaccessible power cables within the scope of Section 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," in Title 10 of the Code of Federal Regulations (i.e., 10 CFR 50.65, the Maintenance Rule). This information was provided to NRC through the auspices of the Nuclear Energy Institute.

The NRC staff has reviewed the cable failure history data in the letter dated May 2, 2007, which was submitted by Wolf Creek Nuclear Operating Corporation in response to GL 2007-01 for the Wolf Creek Generating Station (WCGS) and has determined that additional information is needed to clarify the information that was provided. In the information provided, there are no failures for inaccessible or underground power cables prior to July 10, 1996. Since licensees were required to implement the Maintenance Rule no later than July 10, 1996, it may be that your staff has interpreted GL 2007-01 such that the requested history of failures of power cables within the scope of 10 CFR 50.65 was interpreted as not requesting cable failures that occurred prior to July 10, 1996.

The NRC provided additional guidance to licensees on how they should determine the cable failure history within the scope of GL 2007-01 in the NRC letter dated April 13, 2007, from Michael J. Case (NRC) to James H. Riley (Nuclear Energy Institute) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070940311). In that letter, the NRC stated that the scope of the search of failure data shall not be limited to the date that automated data recording was implemented at the plant and shall include cable failures that can be searched for in a plant electronic database, regardless of the actual date of the failure. There was no restriction as to the date of occurrence of the failure data. Also, the statement in requested information (1) in GL 2007-01, that licensees are requested to provide "a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65" refers to Section 50.65(b)(1) on safety-related structures, systems, and components that come under the Rule.

As explained above, you are requested to confirm by letter that cable failure data provided in response to GL 2007-01 does not include cable failures that occurred prior to 1996, or to provide a schedule as to when this data can be provided. We request your letter within 30 days of the receipt of this letter. If you have any questions concerning this letter, you are requested to contact me at 301-415-1307, or via electronic mail at jnd@nrc.gov. Sincerely,

/RA/ Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-482

cc: See next page

ML072950027 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC

NAME JDonohew JBurkhardt MTMarkley for THiltz DATE 10/24/07 10/25/07 10/25/07 February 2006 Wolf Creek Generating Station

cc:

Jay Silberg, Esq.

Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW Washington, D.C. 20037

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011

Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 311 Burlington, KS 66839

Chief Engineer, Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027

Office of the Governor State of Kansas Topeka, KS 66612

Attorney General 120 S.W. 10 th Avenue, 2 nd Floor Topeka, KS 66612-1597

County Clerk Coffey County Courthouse 110 South 6 th Street Burlington, KS 66839 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366

Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

Supervisor Licensing Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

U.S. Nuclear Regulatory Commission Resident Inspectors Office/Callaway Plant

8201 NRC Road Steedman, MO 65077-1032