ET 15-0015, Response to Request for Additional Information Regarding Expedited Seismic Evaluation Process (ESEP) Report

Response to Request for Additional Information Regarding Expedited Seismic Evaluation Process (ESEP) Report

ML15182A116
Person / Time
Site:	Wolf Creek
Issue date:	06/24/2015
From:	Mccoy J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 15-0015
Download: ML15182A116 (5)

Text

W4ILF CREEK INUCLEAR OPERATING CORPORATION June 24, 2015 Jaime H. McCoy Vice President Engineering ET 15-0015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter dated March 12, 2012, from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident"

2) Letter WO 14-0095 dated December 23, 2014, from C. 0. Reasoner, WCNOC, to USNRC

3) Electronic Mail dated May 28, 2015, from S. M. Wyman, USNRC, to T. W. Solberg, WCNOC

Subject:

Docket No. 50-482: Response to Request for Additional Information Regarding Expedited Seismic Evaluation Process (ESEP) Report Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 to Wolf Creek Nuclear Operating Corporation (WCNOC). The Enclosure of Reference 2 provided the Wolf Creek Generating Station (WCGS) Expedited Seismic Evaluation Process (ESEP) Report requested in Enclosure 1 of Reference 1.

Reference 3 provided a request for additional information related to the WCGS Expedited Seismic Evaluation Process Report. The Attachment provides WCNOC's response to the request for additional information.

c)i D P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET

ET 15-0015 Page 2 of 3 This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Mr. Bill T. Muilenburg at (620) 364-4186.

Sincerely, H. McCoy JHM/rlt Attachment cc: M. L. Dapas (NRC), w/a C. F. Lyon (NRC), w/a A. A. Rosebrook (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 15-0015 Page 3 of 3 STATE OF KANSAS )

COUNTY OF COFFEY )

Jaime H. McCoy, 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.

Jaime V. McCoy Vice 'resident Engineering SUBSCRIBED and sworn to before me this 2 day of -- R. ,2015.

JlwJv 2 GAYLE SHEPHEARD] Notry lbic Notary Public - State of Kansasl My Appt. Expires 0

'y//c:ateci2bo /'5-Expiration Date Expraton

Attachment to ET 15-0015 Page 1 of 2 Response to Request for Additional Information Regarding Expedited Seismic Evaluation Process (ESEP) Report Reference 1 provided the Wolf Creek Generating Station (WCGS) Expedited Seismic Evaluation Process (ESEP) Report. Reference 2 provided a Nuclear Regulatory Commission (NRC) request for additional information (RAI) regarding the WCGS ESEP Report. Provided below are the responses to the questions in the NRC RAI. The specific NRC request is provided in italics.

1. The following SSCs appear to meet the ESEP guidance, but were not included on the ESEL: steam generator atmospheric relief valves (ARVs), accumulators, accumulator isolation valves, and reactor head vent or pressurizer PORV. Please add these components to the ESEL with any associatedsupport equipment and provide results per ESEP guidance (e.g., HCLPF analysis results) or provide a justification why they are not included on the ESEL.

Response: The components in question were not included on the WCGS Expedited Seismic Equipment List (ESEL) because of the exemption "Nuclear Steam Supply System (NSSS)

Components" contained in the Augmented Approach Guidelines (Reference 3, Section 3.2). Without further definition provided, those components considered to be part of the NSSS were designated as the Reactor Coolant System (RCS) and connected systems up to the Main Steam Isolation Valves (MSIVs). Therefore, the components questioned (Steam Generator Atmospheric Relief Valves (ARVs), accumulators, accumulator isolation valves, and reactor head vent and pressurizer Power Operated Relief Valve (PORV)) were not included on the WCGS ESEL.

2. All necessary instrumentation does not appearto be included on the ESEL. Clarify which SSCs are necessary to achieve the following indications and confirm they are included in or added to the ESEL.

a. Steam generatorwater level

b. Steam generatorpressure

c. Containmentpressure

d. RCS pressure

e. RCS Temperature Response: Steam generator water level, steam generator pressure, RCS pressure and RCS temperature were not included on the WCGS ESEL because of the exemption "NSSS Components" contained in the Augmented Approach Guidelines (Reference 3, Section 3.2). Without further definition provided, those components considered to be part of the NSSS were designated as the RCS and connected systems up to the MSIVs. Therefore, steam generator water level, steam generator pressure, RCS pressure, and RCS temperature were not included on the WCGS ESEL.

In the process of screening the containment pressure transmitters, three things were concluded:

1) the containment function was not expected to be challenged per the still-in-progress Overall Integrated Plan (OIP) (Reference 4, Pages G-39, G-40, and G-42),

2) there was no credible mechanism to damage the transmitters, and

Attachment to ET 15-0015 Page 2 of 2

3) the guidance allows the exclusion of Structures (e.g., containment, reactor building, control building, auxiliary building, etc.).

There are no block walls inside containment and small-bore tubing has adequate flexibility to withstand a seismic event. Thus, based on this information, the containment pressure transmitters were not initially included in the WCGS ESEL. However, after further consideration, WCNOC will add containment pressure indication instrumentation to the WCGS ESEL and perform the appropriate evaluation as per the guidance in Reference 3.

3. The licensee did not state whether the walkdown personnel were trained in seismic walkdown. Please confirm that the walkdowns were conducted by trained personnel that successfully completed training specific for seismic, such as the Seismic Qualification Utility Group (SQUG) Walkdown Screening and Seismic Evaluation Training Course.

Response: The walkdowns were performed by: structural engineers that were designated as Seismic Capability Engineers (SCE). Required for that designation, they have completed the Electric Power Research Institute (EPRI) 5-day Seismic Qualification Utility Group (SQUG) training. These are the same engineers that performed the Near-Term Task Force (NTTF) 2.3 Seismic Walkdowns for WCGS.

References:

1. WCNOC Letter WO 14-0095, "Expedited Seismic Evaluation Process Report (CEUS Sites), Response NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," December 23, 2014. ADAMS Accession No. ML14365A262.

.2. Electronic Mail 15-00573 from S. M. Wyman, USNRC, to T. W. Solberg, WCNOC, "Wolf Creek ESEP Clarifications Questions," May 28, 2015.

3. EPRI Report 3002000704. "Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1 - Seismic," May 2013.

4. WCNOC Letter WO 13-0014, "Wolf Creek Nuclear Operating Corporation Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," February 28, 2013. ADAMS Accession No. ML13070A026.