ML071380454

Response to NRC Requests for Additional Information Related to Wolf Creek Generating Station License Renewal Application

ML071380454
Person / Time
Site:	Wolf Creek
Issue date:	05/10/2007
From:	Garrett T Wolf Creek
To:	Document Control Desk, NRC/NRR/ADRO
References
ET 07-0016
Download: ML071380454 (23)

Text

W 'ILF CREEK'NUCLEAR OPERATING CORPORATION May 10, 2007 Terry J. Garrett Vice President, Engineering ET 07-0016 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 06-0038, dated September 27, 2006, from T. J. Garrett, WCNOC, to USNRC 2) Letter dated April 11, 2007, from V. Rodriguez, USNRC, to T. J. Garrett, WCNOC (ML070930659)

3) Letter ET 07-0011, dated May 2, 2007, from T.J Garrett, WCNOC, to USNRC

Subject:

Docket No. 50-482: Response to NRC Requests for Additional Information Related to Wolf Creek Generating Station License Renewal Application Gentlemen:

Reference 1 provided Wolf Creek Nuclear Operating Corporation's (WCNOC) License Renewal Application for the Wolf Creek Generating Station (WCGS). Reference 2 requested additional information regarding the License Renewal Application.

Attachment I provides the WCNOC response to each NRC request.Attachment II provides a comprehensive commitment list including all commitments made in References 1 and 3. The list also includes one additional commitment made in response to Reference 2.If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr. Kevin Moles at (620) 364-4126.Terry J. Garrett TJG/rlt P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET ET 07-0016 Page 2 of 3 Oath Attachment I WCNOC Response to NRC Requests for Additional Information (ML070930695)

Dated April 9, 2007 Attachment II List of Commitments cc: J. N. Donohew (NRC), w/a V. G. Gaddy (NRC), w/a B. S. Mallett (NRC), w/a V. Rodriguez (NRC), w/a Senior Resident Inspector (NRC), w/a ET 07-0016 Page 3 of 3 STATE OF KANSAS))ss COUNTY OF COFFEY )Terry J. Garrett, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering 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_________________

Terry J. Vice President Engineering SUBSCRIBED and sworn to before me this Ib day of fqaj, 2007.Notary Public I MQ.-- Expiration Date Wnliot 11, AND Attachment I to ET 07-0016 Page 1 of 10 Attachment I WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 RAI B.2.1.34-1 RAI B.2.1.34-2 RAI B.2.1.34-3 RAI B.2.1.34-4 RAI B.2.1.34-5 RAI B.2.1.34-6 RAI B.2.1.34-7 RAI B.2.1.34-8 RAI B.2.1.34-9 Attachment I to ET 07-0016 Page 2 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 Nickel Alloy Aging Management Program RAI B.2.1.34-1 The Nickel Alloy Aging Management Program (AMP) was submitted prior to the performance of pre-mitigation weld inspections for the application of weld overlays on pressurizer connections with dissimilar metal butt welds at WCGS. The pre-mitigation inspection performed in 2006 identified extensive circumferential cracking at three dissimilar metals welds associated with surge, relief, and safety nozzles. The staff requests that the applicant revise this AMP to incorporate information pertaining to the dissimilar metals butt weld inspection activities and findings.

The revised AMP should: (1) discuss program enhancements incorporated as a result of the inspections, (2)provide information regarding the mitigation and preventive actions, taken or planned, to reduce the susceptibility of Alloy 600/82/182 components to primary water stress corrosion cracking (PWSCC), (3) discuss the inspection frequency and method of inspection of components susceptible to PWSCC covered under the scope of this program, and (4) provide justification that the AMP will provide reasonable assurance that PWSCC will be detected on a timely matter.In addition, the staff requests that the applicant update the AMP Updated Safety Analysis Report (USAR) supplement to reflect all changes made to the program.RAI B.2.1.34-1 Response The following changes to the Alloy 600 program resulted from the circumferential cracking identified in 2006.(1) Examinations have been added to the program as a result of the 2006 operating experience.

Visual examination of bottom mounted nozzles are performed every other refueling outage. A baseline volumetric examination was performed during Refueling Outage 14 (Spring 2005) on all hot leg nozzles, cold leg nozzles and bottom mounted nozzles.(2) Wolf Creek Nuclear Operating Corporation's (WCNOC) program provides for mitigation of reactor coolant system pipe butt welds containing alloy 600.Mitigation plans are prioritized in accordance with risk rankings listed in WCNOC Procedure "Program Plan for Management of Alloy 600 Components and Alloy 82/182 Welds", WCRE-15 Attachment A. Pressurizer surge, relief, safety, and spray nozzles containing alloy 600 material have been overlayed with alloy 690.WCNOC's program directs subsequent examinations of these nozzles to be performed in accordance with "Primary System Butt Weld Inspection and Evaluation Guideline," Materials Reliability Program (MRP-139).

Options for mitigating reactor coolant loop nozzles are currently being evaluated.

(3) There have been no changes to the frequency or method of inspection other than those identified in (1) and (2) above.

Attachment I to ET 07-0016 Page 3 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 (4) The WCNOC alloy 600 program provides reasonable assurance that primary water stress corrosion cracking (PWSCC) degradation will be detected in a timely manner because examination plans optimize inspection intervals and techniques, and maximize the likelihood of detecting a flaw prior to impact on plant safety and reliability.

Alloy 600 inspection activities are included as augmented actions in the Inservice Inspection (ISI) program, and include bare metal visual (BMV), surface, and volumetric examinations as directed by regulatory and industry guidance.

Inspection of components, where susceptible material is used as a pressure boundary for the primary system, meets or exceeds industry and regulatory guidance.

The program incorporates plant specific and industry operating experience.

WCNOC has taken a proactive approach in mitigating the Pressurizer nozzles via structural weld overlay and has included locations having susceptible material exposed to primary water in the Alloy 600 program. As part of this program WCNOC is considering available options for repairing/mitigating the Reactor loop nozzles. This proactive approach applies to other high risk or high probability locations as well.RAI B.2.1.34-2 PWSCC of components made of Alloy 600/82/182 in pressurized power reactors (PWR)is an emerging material degradation issue. The industry has initiated augmented inspections and mitigation of susceptible components to ensure safe operation of the affected plants. Recent inspection findings of extensive circumferential cracking of Alloy 82/182 dissimilar metal welds at WCGS has raised concerns regarding the adequacy of the inspection scope and schedule based on industry initiatives.

In addition, discussions with the industry to resolve the staff's comments and recommendations to the inspection program delineated in the Materials Reliability Program (MRP)-139, "Primary System Butt Weld Inspection and Evaluation Guideline," is continuing.

Therefore, to ensure that the program is acceptable for implementation during the period of extended operation and that it will manage the effects of aging in accordance with 10 CFR 54.21(a)(3), the staff requests that the applicant commit to continue to participate in industry initiatives (such as the Westinghouse Owners Group and the Electric Power Research Institute MRP.) The program inspection requirements of Alloy 600/82/182 components must be consistent with the latest version of the NRC accepted industry guidance, generic communications, orders, and applicable regulatory requirements delineated in 10 CFR 50.55a. In addition, the staff requests that the applicant submit the AMP inspection plan for NRC review and approval at least 24 months prior to entering the period of extended operation.

RAI B.2.1.34-2 Response Currently, License Renewal Application (LRA) section A1.35 "Reactor Coolant System Supplement" commits Wolf Creek Generating Station (WCGS) to the following regarding Reactor Coolant System Nickel Alloy Pressure Boundary Components:

Attachment I to ET 07-0016 Page 4 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007"Implement applicable (1) NRC Orders, Bulletins and Generic Letters associated with nickel alloys and (2) staff-accepted industry guidelines" LRA section A1.34 "Nickel Alloy Aging Management Program" will be amended to include the following: "The WCGS Nickel Alloy Aging Management inspection plan will be submitted for NRC review and approval at least 24 months prior to entering the period of extended operation." RAI B.2.1.34-3 By letter dated October 12, 2005, the NRC staff provided comments and recommendations to the Nuclear Energy Institute (NEI) pertaining to the guidance provided in MRP-139 for the inspection and evaluation of Alloy 82/182 butt welds. This initiative is continuing and a resolution has not been reached. The staff requests that the applicant identify any exceptions that WCGS plans to take to the NRC's comments and recommendations provided to the NEI. If WCGS plans to take exceptions, the staff requests that the applicant provide its technical justification.

RAI B.2.1.34-3 Response WCNOC is participating with the Nuclear Energy Institute (NEI) to obtain staff acceptance of the guidance provided in MRP-139 for the inspection and evaluation of Alloy 82/182 butt welds.WCNOC may take exception to comment 2 with regard to the statement "that leak before break (LBB) welds shall be mitigated." Although WCNOC is pursuing plans to mitigate our LBB welds, definitive mitigation strategies and dates have not been set.WCNOC takes exception to comment 17. WCNOC does not interpret MRP-139 to permit volumetric coverage less than that required by the ASME code. WCNOC considers MRP section 1.2 to be consistent with ASME code in that WCNOC does not interpret the guidelines set forth in 1.2 to reduce current ASME Code requirements.

RAI B.2.1.34-4 By letter dated July 27, 2004, Wolf Creek Nuclear Operating Corporation (WCNOC)responded to NRC Bulletin 2004-01, "Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors." The staff requests that the applicant confirm that WCGS is not taking any exception to the guidance provided in this bulletin.

If exceptions are identified, the applicant should address and justify them, especially those in the following areas: (1) percentage of inspection coverage to be achieved at each location, and (2) performance of an extent-of-condition evaluation, sample expansion, and Attachment I to ET 07-0016 Page 5 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 non-destructive examinations if circumferential cracking is found. In addition, in view of the extensive PWSCC found at WCGS, the staff requests that the applicant discuss any enhancements made to the WCGS inspection plan for those components addressed in Bulletin 2004-01.RAI B.2.1.34-4 Response The only exception taken to the recommendations of NRC Bulletin 2004-01 was explained in Table I of the response in relation to the spray nozzle to safe-end weld. This exception was part of a relief request submitted by WCNOC (Reference

1) and approved by the NRC (Reference 2).The pressurizer surge, safety, relief and spray nozzles have been overlayed with alloy 690. The pressure boundary in these locations is now the alloy 690 overlay.The original alloy 600 is no longer credited as the pressure boundary.

WCNOC examination criteria uses the guidance of MRP-139.RAI B.2.1.34-5 NRC Bulletin 2003-02, "Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity," requested information from PWR licensees regarding the reactor coolant pressure boundary integrity associated with the reactor pressure vessel lower head penetrations.

WCNOC did not discuss augmented inspection plans for these components in its response to this bulletin nor in its description of the AMP. In view of the extensive PWSCC found at WCGS, the staff requests that the applicant discuss the inspection plan for the components addressed in Bulletin 2003-02, and provide justification for its adequacy.RAI B.2.1.34-5 Response In response to NRC Bulletin 2003-02, WCNOC stated: "A surveillance procedure being developed for inspection of the lower RPV head will be complete by October 19, 2003. This procedure will be performed during the Fall 2003 refueling outage and is also expected to be performed during subsequent refueling outages." In accordance with WCNOC's response to NRC Bulletin 2003-02, WCNOC performed bare metal visual (BMV) examinations of the lower RPV head nozzles (bottom mounted nozzles, (BMN)) during the Fall 2003 and Spring 2005 outages.During the Spring 2005 outage, WCNOC also performed ultrasonic, eddy current and visual examinations of the BMN welds from inside the vessel. No indications were found.As the environmental conditions of the nozzles are similar to the closure head, which requires visual inspections every 3rd refueling, WCNOC has chosen to reduce the frequency of the BMN BMV examinations from each refueling to every other refueling.

Currently, WCNOC plans to conduct BMN BMV (or similar)examinations every other refueling, with additional NDE exams (eddy current, Attachment I to ET 07-0016 Page 6 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 ultrasonic and visual) when the lower core barrel is removed for ISI exams. Exam frequency is based on industry experience and guidance.RAI B.2.1.34-6 The LRA states that the reactor coolant system (RCS) pressure boundary, RCS non-pressure boundary, and ESF locations are included within the scope of this AMP. The staff requests that the applicant identify the components associated with these locations and its corresponding inspection plan. In addition, the staff requests that the applicant identify any Alloy 600/82/182 components not covered within the scope of this program and the reasons for their exclusion.

RAI B.2.1.34-6 Response The nickel alloy program identifies the following Alloy 600 locations and inspection frequencies.

With the exception of Steam Generator tubing, which is managed by the steam generator tubing integrity AMP (XI.M19), all Alloy 600 locations in plant systems are included in the scope of this program.REACTOR VESSELCOMPONENTS (RV)RV Outlet Nozzle Safe-End-Hot Leg -Each Refueling (Bare Metal Visual), Every 5 Years (Volumetric)

RV Head Vent Nozzle -Lesser of 3rd Refueling or 5 Years RV Bottom Mounted Nozzle -Each Refueling (Bare Metal Visual), 10-year ISI Exam (Volumetric)

RV BMN Weld year ISI Exam RV BMN to Guide Tube Weld -Each Refueling RV Inlet Nozzle Safe-End (Cold Leg) Weld -Every 3rd Refueling (Bare Metal Visual), Every 6 Years (Volumetric)

RV Core Support Block at Weld -Once per Interval RV Core Support Block Weld -Once per Interval RV Core Support Block -Once per Interval RV Head Vent to Elbow Weld -Each Refueling RV Head Vent Elbow to Piping Weld -Each Refueling RV Head Vent Pipe to SS Elbow -Each Refueling RV Head Vent Nozzle Elbow -Each Refueling RV Head Vent Horizontal Pipe -Each Refueling Head Vent Penetration Weld -Lesser of 4th Refueling or 7 Years Control Rod Drive Mechanism (CRDM)CRDM Nozzle and Nozzle Weld -Lesser of 4th Refueling or 7 Years CRDM Nozzle -Lesser of 3rd Refueling or 5 Years CRDM to Flange Weld -Each Refueling PRESSURIZER COMPONENTS (PZR)PZR Safety and Relief Nozzle Safe-End Weld -Each Refueling (Bare Metal Visual), Each Period (Volumetric)

Attachment I to ET 07-0016 Page 7 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 PZR Surge Line Nozzle Safe-End Weld -Each Refueling (Bare Metal Visual), Each Period (Volumetric)

PZR Spray Nozzle Safe-End Weld -Each Refueling (Bare Metal Visual), Each Period (Volumetric)

STEAM GENERATOR COMPONENTS (SIG)SG Partition Plate-Hot Leg -Each Period SG Partition Stub-Hot Leg -Generator Maintenance SG Partition Stub/Tubesheet Weld-Hot Leg -Generator Maintenance SG Partition Plate/Stub Weld-Hot Leg -Generator Maintenance SG Closure Ring-Hot Leg -Generator Maintenance SG Cladding on CS Shell-Hot Leg -Generator Maintenance SG Partition Plate/Lower Bowl Weld-Hot Leg -Generator Maintenance SG Closure Ring Weld-Hot Leg -Generator Maintenance SG Partition Plate-Cold Leg -Generator Maintenance SG Partition Stub-Cold Leg -Generator Maintenance SG Tubesheet and Radius Cladding-Hot Leg -Generator Maintenance SG Partition Stub/Tubesheet Weld-Cold Leg -Generator Maintenance SG Partition Plate/Stub Weld-Cold Leg -Generator Maintenance SG Closure Ring-Cold Leg -Generator Maintenance SG Closure Ring Weld-Cold Leg -Generator Maintenance SG Drain Pipe -Each Refueling SG Cladding on CS Shell-Cold Leg -Generator Maintenance SG Partition Plate/Lower Bowl Weld-Cold Leg -Generator Maintenance SG Tubesheet and Radius Cladding-Cold Leg -Generator Maintenance REACTOR COOLANT PIPING COMPONENTS (RCS)RCS Hot Leg Thermowells

-Each Refueling RCS Cold Leg Thermowells

-Each Refueling ENGINEERED SAFETY FEATURES COMPONENTS (ESF)Accumulator Nozzles (All Alloy 82/182 Welds) -ISI Period Note: The pressurizer surge, safety, relief and spray nozzles have been overlayed with alloy 690. The pressure boundary in these locations is now the alloy 690 overlay. The original alloy 600 is no longer credited as the pressure boundary.RAI B.2.1.34-7 The detection of aging effects program element states that this AMP utilizes various visual, surface and volumetric inspections and examination techniques for early detection of PWSCC in Alloy 600 components.

However, it does not specify whether the equipment, method and personnel used for these inspections meet the ASME Code Section XI requirements.

The staff requests that the applicant revise the LRA to clarify this statement.

Attachment I to ET 07-0016 Page 8 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 RAI B.2.1.34-7 Response The equipment, methods and personnel used for alloy 600 examinations are in accordance with applicable regulatory or code requirements (NRC Order EA-03-009 or ASME Section Xl) or industry standard (MRP-139). (Reference WCNOC Procedure "Alloy 600 Program Management", AP 29A-007 Step 6.4). WCNOC procedure "Alloy 600 Program Management", AP 29A-007 Attachment A, identifies the locations examined and the examination technique utilized.

WCNOC procedure "Program Plan for Management of Alloy 600 Components and Alloy 82/182 Welds", WCRE-15 Section 4.1, describes the requirements for each examination technique.

A summary of the requirements for equipment, methods and personnel used for alloy 600 examinations is provided below.VT-2 exams are performed under procedures written to meet the requirements of ASME Section Xl code. Equipment utilized must be in accordance with Section Xl and the personnel performing the exam must be qualified to a minimum Level II in VT-2 method examinations.

Bare Metal Visual (BMV) exams are performed utilizing a procedure that meets the VT-2 requirements of ASME Section Xl with the additional requirements that the surface of the component be visible. Remote video equipment is allowed but must be demonstrated to have the ability to fulfill detection requirements.

Personnel performing the exam must be qualified to a minimum of Level II in VT-2 method with additional training in the detection of Boric Acid leakage/corrosion.

Surface exams are performed in accordance with Section Xl for method, equipment and personnel qualification requirements.

Code required Volumetric Exams are in accordance with Appendix VIII of ASME Section Xl.Non-Code required exams are in accordance with the appropriate industry standard with equipment and procedure demonstrations as required.

These are exams required by the NRC such as under head exams as well as voluntary exams of BMN's and are performed using personnel, equipment, and procedures qualified by performance demonstrated methodology.

RAI B.2.1.34-8 The monitoring and trending program element states that relative risk rankings for Alloy 600 locations are included as part of this AMP. The staff requests that the applicant address how the relative risk rankings will be used in the inspection of Alloy 600/82/182 components and whether this ranking methodology was approved by the NRC.

Attachment I to ET 07-0016 Page 9 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 RAI B.2.1.34-8 Response The ranking system is used to prioritize the expenditure of resources for mitigation, replacement, or additional inspections beyond regulatory/industry requirements.

WCAP 16228-P provided the initial relative risk ranking for Alloy 600182/182 reactor coolant system locations at WCNOC. The NRC has not approved this methodology.

RAI B.2.1.34-9 The corrective actions program element states that "Corrective actions may be used as tracking and documentation records for changes in plant thought processes and to identify potential improvement in programs from benchmarking activities." The staff requests that the applicant provide details and examples to clarify this statement.

RAI B.2.1.34-9 Response Evaluations of WCNOC and industry operating experience have been documented in the WCNOC corrective action program and improvements have been factored into the WCNOC Alloy 600 program. Examples follow below.Performance Improvement Request (PIR) 2003-1450 established the need to develop an Alloy 600 program plan to manage issues associated with Alloy 600 and associated weld material 821182, prior to issuance of MRP-126. The PIR was modified in December 2004 to reference MRP-126 as an industry document that outlined mandatory requirements in establishing a plant program for Alloy 600.PIR 2005-0174 documents evaluation of Westinghouse Technical bulletin TB-04-19, "Steam Generator Channel Head Bowl Drain Line Leakage".

The evaluation determined that the bulletin was applicable to WCGS and that the recommendations of the bulletin had been previously captured in the Alloy 600 program.PIR 2006-0196 documents WCNOC's evaluation of the EPRI NDE Steering Committee recommendation to consider radiography testing (RT) techniques for detection of PWSCC in Alloy 600 weldments.

The WCNOC evaluation determined that ultra sonic testing (UT) and eddy current testing (ET) are still the methods of choice.Condition Report (CR) 2006-002468 documents WCNOC evaluation of UT indications found on the Pressurizer Pressure Operated Relief Valve (PORV)nozzle and on Pressurizer safety nozzle C. The most probable mechanism responsible for the detected flaws was determined to be PWSCC. The evaluation also identified that prior to Refueling Outage (RF15), most identified susceptible welds capable of volumetric examination had been examined by volumetric inspection at least once since plant startup as part of the plant ASME Section Xl Attachment I to ET 07-0016 Page 10 of 10 WCNOC Response to NRC Requests for Additional Information (ML070930659)

Dated April 11, 2007 ISI program, but some of the volumetric inspections were performed using procedures, equipment, and personnel that did not meet current qualification requirements.

However, subsequent to RF 15, all welds and components with high susceptibility to PWSCC at WCGS had been inspected by "state-of-the-art" non-destructive examination (NDE) techniques or had been repaired/mitigated to remove the susceptibility.

For example, the steam generator bowl drain coupling welds were removed in RF 14 and replaced with Alloy 52, which is considered to be resistant to PWSCC. All of the pressurizer nozzles were inspected during Refuel 15 and full structural weld overlays were applied to all nozzles during that outage. The evaluation determined that all locations of equivalent susceptibility to the nozzles where flaws were found, as well as other locations with high-risk significance, such as the reactor vessel outlet nozzles, bottom mounted nozzles and Control Rod Drive Mechanism (CRDM) nozzles, were repaired or examined using qualified techniques during Refuel 14 and Refuel 15. The evaluation concluded that all items in Table 5-1 of WCAP-16228-P had been examined or repaired/mitigated, and other potentially susceptible locations, in lower susceptibility categories, would continue to be monitored in accordance with WCNOC procedures (AP 29A-007 and WCRE-15).

References:

1) Letter ET 01-0009, dated February 5, 2001, from R. A. Muench, WCNOC, to USNRC.2) Letter dated December 13, 2001, from, Stephen Dembek, USNRC, to Otto L.Maynard, WCNOC.

Attachment II to ET 07-0016 Page 1 of 10 Attachment II List of Commitments Attachment II to ET 07-0016 Page 2 of 10 LICENSE RENEWAL APPLICATION

-LIST OF REGULATORY COMMITMENTS The following table identifies a summary of those actions committed to by Wolf Creek Nuclear Operating Corporation (WCNOC) in the License Renewal Application (LRA) and subsequent requests for additional information.

Any other statements in this submittal, are provided for information purposes and are not considered to be commitments.

Please direct questions regarding these commitments to Mr. Kevin Moles at (620) 364-4126.COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 1 Boric Acid Corrosion A1.4 Prior to the period of extended operation, Program procedures will be enhanced to state that (RCMS 2006-198) susceptible components adjacent to potential leakage sources will include electrical components and connectors.

Reference:

ET 06-0038 Due: March 11, 2025 2 Nickel-Alloy Penetration A1.5 Prior to the period of extended operation, Nozzles Welded To The procedures will be enhanced to indicate that Upper Reactor Vessel detection of leakage or evidence of cracking Closure Heads of in the vessel head penetration nozzles or Pressurized Water associated welds will cause an immediate Reactors reclassification to the "High" susceptibility (RCMS 2006-199) ranking, commencing from the same outage in which the leakage or cracking is detected.

Reference:

ET 06-0038 Due: March 11, 2025 3 Closed-Cycle Cooling A1.10 Prior to the period of extended operation, a Water System new periodic preventive maintenance (RCMS 2006-200) activity will be developed to specify performing inspections of the internal surfaces of valve bodies and accessible piping while the valves are disassembled for operational readiness inspections to detect loss of material and fouling.

Reference:

ET 06-0038 Due: March 11, 2025 Attachment II to ET 07-0016 Page 3 of 10 COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 4 Inspection of Overhead Al.11 Prior to the period of extended operation, Heavy Load and Light procedures will be enhanced to: (1) identify Load (Related to industry standards or Wolf Creek Refueling)

Handling Generating Station (WCGS) specifications Systems that are applicable to the component, and (RCMS 2006-201)

(2) specifically inspect for loss of material due to corrosion or rail wear.

Reference:

ET 06-0038 Due: March 11, 2025 5 Fire Protection A1.12 Prior to the period of extended operation: (RCMS 2006-202)

(1) fire damper inspection and drop test procedures will be enhanced to inspect damper housing for signs of corrosion, (2)fire barrier and fire door inspection procedures will be enhanced to specify fire barriers and doors described in USAR Appendix 9.5A, 'WCGS Fire Protection Comparison to APCSB 9.5-1 Appendix A", and WCGS Fire Hazards Analysis, and (3)training for technicians performing the fire door and fire damper visual inspection will be enhanced to include fire protection inspection requirements and training documentation.

Reference:

ET 06-0038 Due: March 11, 2025 6 Fuel Oil Chemistry Al.14 Prior to the period of extended operation: (RCMS 2006-203 (1) the emergency fuel oil day tanks will be added to the ten year drain, clean, and internal inspection program, and (2)procedures will be enhanced to provide for supplemental ultrasonic thickness measurements if there are indications of reduced cross sectional thickness found during the visual inspection of the emergency fuel oil storage tanks.

Reference:

ET 06-0038 Due: March 11, 2025 Attachment II to ET 07-0016 Page 4 of 10 COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 7 One-Time Inspection A1.16 The One-Time Inspection program (RCMS 2006-204) conducts one-time inspections of plant system piping and components to verify the effectiveness of the Water Chemistry program (Al.2), Fuel Oil Chemistry program (A1.14), and Lubricating Oil Analysis program (Al.23).This new program will be implemented and completed within the ten-year period prior to the period of extended operation.

Reference:

ET 06-0038 Due: March 11, 2025 8 Selective Leaching of Al.17 The Selective Leaching of Materials Materials program is a new program that will be (RCMS 2006-205) implemented prior to the period of extended operation.

Reference:

ET 06-0038 Due: March 11, 2025 9 Buried Piping and Tanks A1.18 The Buried Piping and Tanks Inspection Inspection program is a new program that will be (RCMS 2006-206) implemented prior to the period of extended operation.

Within the ten-year period prior to entering the period of extended operation, an opportunistic or planned inspection will be performed.

Upon entering the period of extended operation a planned inspection within ten years will be required unless an opportunistic inspection has occurred within this ten-year period.

Reference:

ET 06-0038 Due: March 11, 2025 10 One-Time Inspection of A1.19 The fourth interval of the ISI program at ASME Code Class 1 WCGS will provide the results for the one Small-Bore Piping (RCMS time inspection of ASME Code Class 1 2006-207) small-bore piping.

Reference:

ET 06-0038 Due: March 11, 2025 Attachment II to ET 07-0016 Page 5 of 10 COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 11 Inspection of Internal A1.22 The Inspection of Internal Surfaces in Surfaces in Miscellaneous Miscellaneous Piping and Ducting Piping and Ducting Components program is a new program Components that will be implemented prior to the period (RCMS 2006-208) of extended operation.

For those systems or components where inspections of opportunity are insufficient, an inspection will be conducted prior to the period of extended operation to provide reasonable assurance that the intended functions are maintained.

Reference:

ET 06-0038 Due: March 11, 2025 12 Electrical Cables and A1.24 The Electrical Cables and Connections Not Connections Not Subject Subject to 10 CFR 50.49 Environmental to 10 CFR 50.49 Qualification Requirements program is a Environmental new program that will be implemented prior Qualification Requirements to the period of extended operation.(RCMS 2006-209)

Reference:

ET 06-0038 Due: March 11, 2025 13 Electrical Cables Not A1.25 A review of the calibration surveillance test Subject to 10 CFR 50.49 results will be completed before the period Environmental of extended operation and every 10 years Qualification Requirements thereafter.

Used in Instrumentation

Reference:

ET 06-0038 Due: March 11, 2025 Circuits (RCMS 2006-210)14 Inaccessible Medium A1.26 The Inaccessible Medium Voltage Cables Voltage Cables Not Not Subject to 10 CFR 50.49 Environmental Subject to 10 CFR 50.49 Qualification Requirements program is a Environmental new program that will be implemented prior Qualification Requirements to the period of extended operation.(RCMS 2006-211)

Reference:

ET 06-0038 Due: March 11, 2025 Attachment II to ET 07-0016 Page 6 of 10 COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 15 ASME Section XI, A1.28 Prior to the period of extended operation, Subsection IWL procedures will be enhanced to include two (RCMS 2006-212) new provisions regarding inspection of repair/replacement activities.

The 2003 edition of ASME Section Xl, Subsection IWL, Article IWL-2000, includes two provisions that are not required by the 1998 edition. IWL-2410(d) specifies additional inspections for concrete surface areas affected by a repair/replacement activity, and IWL-2521.2 specifies additional inspections for tendons affected by a repair/replacement activity.

In accordance with 10 CFR 50.55a, WCGS will revise their CISI program prior to the next inspection interval to incorporate the ASME Code edition and addenda incorporated into 10 CFR 50.55a at that time.

Reference:

ET 06-0038 Due: March 11, 2025 16 Masonry Wall Program A1.31 Prior to the period of extended operation, (RCMS 2006-213) procedures will be enhanced to identify un-reinforced masonry in the Radwaste Building within the scope of license renewal that requires aging management.

Reference:

ET 06-0038 Due: March 11, 2025 17 Structures Monitoring A1.32 Prior to the period of extended operation, Program procedures will be enhanced to add (RCMS 2006-214) inspection parameters for treated wood.

Reference:

ET 06-0038 Due: March 11, 2025 18 RG 1.127, Inspection of A1.33 Prior to the period of extended operation, Water-Control Structures procedures will be enhanced:

(1) so that the Associated with Nuclear main dam service spillway and the auxiliary Power Plants spillway will be inspected in accordance (RCMS 2006-215) with the same specification, (2) to clarify the scope of inspections for the spillways, (3) to add the 5 year inspection frequency for the main dam service spillway, and (4) to add cavitation to the list of concrete aging effects for surfaces other than spillways.

Reference:

ET 06-0038 Due: March 11, 2025 Attachment II to ET 07-0016 Page 7 of 10 COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 19 Reactor Coolant System A1.35 WCNOC will: Supplement A. Reactor Coolant System Nickel Alloy (RCMS 2006-216)

Pressure Boundary Components Implement applicable (1) NRC Orders, Bulletins and Generic Letters associated with nickel alloys and (2) staff-accepted industry guidelines, and B. Reactor Vessel Internals (1) Participate in the industry programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, WCNOC will submit an inspection plan for reactor internals to the NRC for review and approval.

Reference:

ET 06-0038 A.,B(1),(2)

Due: March 11, 2025 B(3) Due: March 11, 2023 20 Electrical Cable A1.36 Prior to the period of extended operation, Connections Not Subject the infrared thermography testing procedure To 10 CFR 50.49 will be enhanced to require an engineering Environmental evaluation when test acceptance criteria are Qualification Requirements not met. This engineering evaluation will (RCMS 2006-217) include identifying the extent of condition, the potential root cause for not meeting the test acceptance, and the likelihood of recurrence.

Reference:

ET 06-0038 Due: March 11, 2025 Attachment II to ET 07-0016 Page 8 of 10 COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 21 Metal Fatigue of Reactor Coolant Pressure Boundary (RCMS 2006-218)A2.1 Prior to the period of extended operation, the Metal Fatigue of Reactor Coolant Pressure Boundary program will be enhanced to include: (1) Action levels to ensure that if the fatigue usage factor calculated by the code analysis is reached at any monitored location, appropriate evaluations and actions will be invoked to maintain the analytical basis of the leak-before-break (LBB) analysis and of the high-energy line break (HELB) locations, or to revise them as required, (2) Action levels to ensurethat appropriate evaluations and actions will be invoked to maintain the bases of safety determinations that depend upon fatigue analyses, if the fatigue usage factor at any monitored location approaches 1.0, or if the fatigue usage factor at any monitored NUREG/CR6260 location approaches 1.0 when multiplied by the environmental effect factor FEN, (3)Corrective actions, on approach to these action levels, that will determine whether the scope of the monitoring program must be enlarged to include additional affected reactor coolant pressure boundary locations in order to ensure that additional locations do not approach the code limit without an appropriate action, and to ensure that the bases of the LBB and HELB analyses are maintained, (4) 10 CFR 50 Appendix B procedural and record requirements.

Prior to the period of extended operation, changes in available monitoring technology or in the analyses themselves may permit different action limits and action statements, or may re-define the program features and actions required to address the fatigue time-limited aging analyses (TLAAs).

Reference:

ET 06-0038 Due: March 11, 2025 Attachment II to ET 07-0016 Page 9 of 10 COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 22 Environmental A2.2 Prior to the period of extended operation, Qualification of Electrical program documents will be enhanced to Components describe methods that may be used for (RCMS 2006-219) qualified life evaluations for the period of extended operation.

Reference:

ET 06-0038 Due: March 11, 2025 23 Concrete Containment A2.3 Prior to the period of extended operation, Tendon Prestress procedures will be revised to: (1) extend the (RCMS 2006-220) list of surveillance tendons to include random samples for the year 40, 45, 50, and 55 year surveillances, (2) explicitly require a regression analysis for each tendon group after every surveillance, (3)invoke and describe regression analysis methods used to construct the lift-off trend lines, (4) extend surveillance program predicted force lines for the vertical and hoop tendon groups to 60 years, and (5)conform procedure descriptions of acceptance criteria action levels to the ASME Code, Subsection IWL 3221 descriptions.

Reference:

ET 06-0038 Due: March 11, 2025 24 ASME III Subsection NG A3.2.2 WCNOC will obtain a design report Fatigue Analysis of amendment to either quantify the increase Reactor Pressure Vessel in high-cycle fatigue effects, or to confirm Internals that the increase will be negligible.(RCMS 2006-221)

WCNOC will complete this action before the end of the current licensed operating period.

Reference:

ET 06-0038 Due: March 11, 2025 25 Assumed Thermal Cycle A3.2.4 WCNOC will complete the reanalysis of the Count for Allowable reactor coolant sample lines and any Secondary Stress Range additional corrective actions or Reduction Factor in B31.1 modifications indicated by them, before the and ASME III Class 2 and end of the current licensed operating 3 Piping (RCMS 2006-222) period.

Reference:

ET 06-0038 Due: March 11, 2025 Attachment II to ET 07-0016 Page 10 of 10 COMMITMENT LRA, SUBJECT Appendix A, COMMITMENT DESCRIPTION Section 26 USAR Supplement AO Following issuance of the renewed (RCMS 2006-223) operating license in accordance with 10 CFR 50.71 (e), WCNOC will incorporate the USAR supplement into the WCGS USAR as required by 54.21(d).

Reference:

ET 06-0038 Due: March 11, 2025 27 Pressure-Temperature (P- A3.1.3 WCNOC will revise the Pressure and T) Limits (RCMS 2006- Temperature Limits Report for a 60-year 224) licensed operating life.

Reference:

ET 06-0038 Due: March 11, 2025 28 Implementation of New N/A Implementation of new programs may Programs require additional action items not included (RCMS 2006-225) in this list. WCGS is committed to including new program elements in the corrective action program.

Reference:

ET 06-0038 Due: March 11, 2025 29 LRA Amendment N/A License Renewal Application changes discussed in ET 07-0011 will be submitted in an amendment to the Application.

Reference:

ET 07-0011 Due: July 20, 2007 30 Nickel Alloy Aging A1.34 The WCGS Nickel Alloy Aging Management Management Program inspection plan will be submitted for NRC review and approval at least 24 months prior to entering the period of extended operation

Reference:

ET 07-0016 Due: March 11, 2023