WO 04-0027, Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process

ML042110340
Person / Time
Site:	Wolf Creek
Issue date:	07/23/2004
From:	Jacobs D Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WO 04-0027
Download: ML042110340 (30)

Text

WOLF CREEK--

'NUCLEAR OPERATING CORPORATION Donna Jacobs Vice President Operations and Plant Manager JUL 2 3 2004 WO 04-0027 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482:

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process Gentlemen:

Pursuant to 10 CFR 50.90, Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS).

The proposed amendment will delete the Technical Specification (TS) requirements related to hydrogen recombiners and hydrogen monitors.

The proposed TS changes support implementation of the revisions to 10 CFR 50.55, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, 'Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP).

Attachment I provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments.

Attachment II provides the existing TS pages marked-up to show the proposed change. Attachment IlIl provides revised, clean TS pages. Attachment IV contains the TS Bases changes (for information only) to assist the staff in its review of the proposed changes. Revision to the TS Bases will be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment. Attachment V contains a list of commitments.

This amendment application was reviewed by the Plant Safety Review Committee and the Nuclear Safety Review Committee.

In accordance with 10 CFR 50.91, a copy of this amendment application, with attachments, is being provided to the designated Kansas State official.

P.O. Box 411/ Burlington, KS 66839/ Phone: (620) 364.8831 f

Ck

(

An Equal Opportunity Employer MIFIHC/VET

WO 04-0027 Page 2 of 2 WCNOC requests approval of the proposed amendment by July 29, 2005. The changes proposed are not required to address an immediate safety concern. It is anticipated that the license amendment, as approved, will be effective upon issuance, to be implemented within 90 days from the date of issuance. Please contact me at (620) 364-4246 or Mr. Kevin Moles at (620) 364-4126 for any questions you may have regarding this application.

Very truly yours, Don Jacobs DJ/rig

-- Attachments:

I Evaluation 11 -

Markup of Technical Specification pages III Retyped Technical Specification pages IV TS Bases Changes (For Information Only)

V List of Commitments cc:

V. L. Cooper (KDHE), w/a J. N. Donohew (NRC), w/a D. N. Graves (NRC), w/a B. S. Mallett (NRC), w/a Senior Resident Inspector (NRC), w/a

STATE OF KANSAS

)

) SS, COUNTY OF COFFEY )

Donna Jacobs, of lawful age,--being first duly sworn upon oath says that she is Vice President Operations and Plant Manager of Wolf Creek Nuclear Operating Corporation; that she has read the foregoing document and knows-the contents thereof; that she 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 her knowledge, information and belief.

and Plant Manager SUBSCRIBED and sworn to before me this 3 day of 9J, 2004.

Ift RHONDAL L

S~ATOFKASAS EtiVpL I

bdooa4c X.- j i J

-Notary Public Expiration Date %tnin1 CJ

'-)PDg

- I 1i,DO(o

Attachment I to WO 04-0027 Attachment I to WO 04-0027 Page 1 of 3 EVALUATION

1.0 DESCRIPTION

The proposed amendment deletes Technical Specification (TS) 3.6.8, 'Hydrogen Recombiners,"

and references to the hydrogen monitors in TS 3.3.3, "Post Accident Monitoring (PAM)

Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors,"

that became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, 'Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 (68 FR 55416) as part of the consolidated line item improvement process.

2.0 PROPOSED CHANGE

Due to minor differences between Wolf Creek Generating Station (WCGS) TS and TS Bases and the model Standard Technical Specifications in NUREG-1431, Revision 2, "Standard Technical Specifications, Westinghouse Plants," in several cases variances from the TSTF mark-up changes are made. These variances are discussed below and do not invalidate the NRC staff's model safety evaluation supporting the adoption of TSTF-447, Revision 1.

Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

• In TS 3.3.3, the Note in Condition C indicating this Condition is not applicable to hydrogen analyzer channels is deleted.

• In TS 3.3.3, Condition D is deleted. Deletion of Condition D resulted in revisions to the lettering of subsequent Conditions in the ACTIONS Table and in Table 3.3.3-1.

• In TS Table 3.3.3-1, Function 10, "Containment Hydrogen Concentration Level," is deleted.

This is a minor variance from TSTF-447 in that Function 11, "Hydrogen Monitors," is deleted and Function 10 is identified as "Not Used" in lieu of renumbering the subsequent Functions to minimize changes to plant procedures.

• TS 3.6.8, "Hydrogen Recombiners," is deleted. The Table of Contents, page ii, is revised to reflect the deletion of TS 3.6.8. The change to the Table of Contents is a minor variance from TSTF-447 in that this change is not reflected in the TSTF.

• TS 5.6.8, "PAM Report," is revised to reflect changing Condition G to Condition F in TS 3.3.3.

As described in NRC-approved Revision 1 of TSTF-447, the changes to TS requirements results in changes to various TS Bases sections. Revision to the TS Bases will be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment.

Attachment I to WO 04-0027 Page 2 of 3

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), NRC Notice for Comment published August 2, 2002 (67 FR 50374), TSTF-477 (Revision 1), the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 TECHNICAL ANALYSIS

Wolf Creek Nuclear Operating Corporation (WCNOC) has reviewed the model safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability.

This verification included a review of the NRC staff's SE, as well as the information provided to support TSTF-447, Revision 1. WCNOC has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to the Wolf Creek Generating Station (WCGS) and justify this amendment for the incorporation of the changes to the WCGS TS.

5.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447 (Revision 1), the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.1 VERIFICATION AND COMMITMENTS As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for the TS improvement, WCNOC is making the following verifications and regulatory commitments:

1.

WCNOC has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at WCGS and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Technical Requirements Manual.

This regulatory commitment will be implemented within 90 days of NRC approval of this amendment request.

2.

WCGS does not have an inerted containment.

5.2 NO SIGNIFICANT HAZARDS CONSIDERATION WCNOC has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP. WCNOC has concluded that the proposed determination presented in the notice is applicable to WCGS and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

Attachment I to WO 04-0027 Page 3 of 3

6.0 ENVIRONMENTAL CONSIDERATION

WCNOC has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. WCNOC has concluded that the staff's findings presented in that evaluation are applicable to WCGS and the evaluation is hereby incorporated by reference for this application.

7.0 REFERENCES

1.

Federal Register Notice:

Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

2.

Federal Register Notice:

Combustible Gas Control in Containment, Proposed Rule published August 2, 2002 (67 FR 50374)

3.

Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," Revision 1.

4.

Federal Register Notice: Combustible Gas Control in Containment, Final Rule published September 16, 2003 (68 FR 54123)

This application is being made in accordance with the CLIIP. Due to minor differences between Wolf Creek Generating Station (WCGS) TS and TS Bases and the model Standard Technical Specifications in NUREG-1431, Revision 2, 'Standard Technical Specifications, Westinghouse Plants," in several cases variances from the TSTF mark-up changes are made. WCNOC is not proposing variations or deviations from the NRC staff's model SE published on September 25, 2003 (68 FR 55416).

1 to WO 04-0027 Page 1 of 8 ATTACHMENT 11 MARKUP OF TECHNICAL SPECIFICATION PAGES

Attachment II to WO 04-0027 Page 2 of 8 TABLE OF CONTENTS 3.3 3.3.6 3.3.7 3.3.8 3.4 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.4.6 3.4.7 3.4.8 3.4.9 3.4.10 3.4.11 3.4.12 3.4.13 3.4.14 3.4.15 3.4.16 3.5 3.5.1 3.5.2 3.5.3 3.5.4 3.5.5 INSTRUMENTATION (continued)

Containment Purge Isolation Instrumentation................................... 3.3-46 Control Room Emergency Ventilation System (CREVS)

Actuation Instrumentation....

3.3-50 Emergency Exhaust System (EES) Actuation Instrumentation............................................................................ 3.3-55 REACTOR COOLANT SYSTEM (RCS)..............................................

3.4-1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits..............................................

3.4-1 RCS Minimum Temperature for Criticality......................................... 3.4-5 RCS Pressure and Temperature (P/T) Limits................................... 3.4-6 RCS Loops - MODES 1 and 2...................

........................... 3.4-8 RCS Loops - MODE 3..............................................

3.4-9 RCS Loops - MODE 4..............................................

3.4-12 RCS Loops - MODE 5, Loops Filled..............................................

3.4-14 RCS Loops - MODE 5, Loops Not Filled........................................... 3.4-17 Pressurizer........................................................................................ 3.4-19 Pressurizer Safety Valves............

.................................. 3.4-21 Pressurizer Power Operated Relief Valves (PORVs)....................... 3.4-23 Low Temperature Overpressure Protection (LTOP) System............ 3.4-26 RCS Operational LEAKAGE..............................................

3.4-31 RCS Pressure Isolation Valve (PIV) Leakage................

.................. 3.4-33 RCS Leakage Detection Instrumentation.......................................... 3.4-37 RCS Specific Activity..............................................

3.4-41 I

EMERGENCY CORE COOLING SYSTEMS (ECCS)..............................

A ccum ulators.....................................................................................

ECCS - O perating..............................................................................

ECCS - Shutdow n.............................................................................

Refueling Water Storage Tank (RWST)...........................................

Seal Injection Flow............................................................................

3.5-1 3.5-1 3.5-3 3.5-6 3.5-8 3.5-10 3.6 CONTAINMENT SYSTEMS.................................

3.6-1 3.6.1 Containment.................................

3.6-1 3.6.2 Containment Air Locks.................................

3.6-2 3.6.3 Containment Isolation Valves.................................

3.6-7 3.6.4 Containment Pressure.................................

3.6-15 3.6.5 Containment Air Temperature................................. 3.6-16 3.6.6 Containment Spray and Cooling Systems................................. 3.6-17 3.6.7 Spray Additive Syt 3.6-20 3t.8 fr r yt i e.

,/

/

Wolf Creek - Unit I ii Amendment No. 423,131

Attachment II to W4 Page 3 of 8 an~p 8 AA5 Fgt 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation PAM Instrumentation 3.3.3 LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2 and 3.

ACTIONS

-NOTES

1. LCO 3.0.4 is not applicable.

2. Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Functions A.1 Restore required channel 30 days with one required channel to OPERABLE status.

inoperable.

B.

Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A not Specification 5.6.8.

met.

(continued)

Wolf Creek - Unit 1 3.3-37 Amendment No. 123

Attachment II to WO 04-0027 Page 4 of 8 PAM Instrumentation 3.3.3 Required Action and associated Completion Time of Condition C g not met.

I As required by Required ActiorLgJand referenced

~

in Table 3.3.3-1.

O@

As req ' 'd by Required Ato nd referenced able 3.3.3-1.

I Wolf Creek - Unit 1 3.3-38 Amendment No. 123

Attachment II to WO 04-0027 PAM Instrumentation Page 5 of 8 333 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUI ED FUNCTION REQUIRED CHANNELS ACTION )

1.

Neutron Flux 2

2.

Reactor Coolant System (RCS) Hot Leg Temperature 2

(Wide Range)

3.

RCS Cold Leg Temperature (Wide Range) 2

4.

RCS Pressure (Wide Range) 2

5.

Reactor Vessel Water Level 2

6.

Containment Normal Sump Water Level 2

7.

Containment Pressure (Normal Range) 2

8.

Steam Line Pressure 2 per 3 )

F~ct sed)steam generator

9.

Containment Radiation Level (High Range) 2

11.

Pressurizer Water Level 2

12.

Steam Generator Water Level (Wide Range) 4

13.

Steam Generator Water Level (Narrow Range) 2 per steam generator

14.

Core Exit Temperature - Quadrant I 2(a)

15.

Core Exit Temperature - Quadrant 2 2(a)

16.

Core Exit Temperature - Quadrant 3 2(a)

17.

Core Exit Temperature - Quadrant 4 2(a)

18.

Auxiliary Feedwater Flow Rate 4

19.

Refueling Water Storage Tank Level 2

(a)

A channel consists of two core exit thermocouples (CETs).

Wolf Creek - Unit 1 3.3-40 Amendment No. 123

Attachment II to WO 04-0027 Page 6 of 8 OPERABLE.

-NOTE-LCO 3.0.4 is not applicable.

/

Restore oneprg recombinPE E

7PAIBLE status.

Wolf Creek - Unit I 3.6-22 Amendment No. 123

Attachment II to WO 04-0027 Page 7 of 8 Wolf Creek - Unit I 3.6-23 Amendment No. 123

Attachment II to WO 04-0027 Page 8 of 8 Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) (continued)

1.

NRC letter dated December 2, 1999, 'Wolf Creek Generating Station, Acceptance for Referencing of Pressure Temperature Limits Report (TAC No. MA4572)," and

2.

WCAP-1 4040-NP-A, 'Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves," January, 1996.

c.

The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

5.6.7 Not Used.

5.6.8 PAM Report When a report is required by Condition B oriof LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.9 Not Used.

5.6.10 Steam Generator Tube Inspection Report

a.

Within 15 days following the completion of each inservice inspection of steam generator tubes, the number of tubes plugged in each steam generator shall be reported to the Commission.

b.

The complete results of the steam generator tube inservice inspection shall be submitted to the Commission in a report within 12 months following completion of the inspection. This Special Report shall include:

1)

Number and extent of tubes inspected, (continued)

Wolf Creek - Unit 1 5.0-30 Amendment No. 123,130 142 I

Attachment III to WO 04-0027 Page 1 of 5 ATTACHMENT III RETYPED TECHNICAL SPECIFICATION PAGES

TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.6 Containment Purge Isolation Instrumentation.................................. 3.3-46 3.3.7 Control Room Emergency Ventilation System (CREVS)

Actuation Instrumentation.3.3-50 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation...........................................................................

3.3-55 3.4 REACTOR COOLANT SYSTEM (RCS).3.4-1 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits.3.4-1 3.4.2 RCS Minimum Temperature for Criticality.3.4-5 3.4.3 RCS Pressure and Temperature (PIT) Limits.3.4-6 3.4.4 RCS Loops - MODES I and 2.3.4-8 3.4.5 RCS Loops - MODE 3.3.4-9 3.4.6 RCS Loops - MODE 4.3.4-12 3.4.7 RCS Loops - MODE 5, Loops Filled.3.4-14 3.4.8 RCS Loops - MODE 5, Loops Not Filled.3.4-17 3.4.9 Pressurizer.3.4-19 3.4.10 Pressurizer Safety Valves.3.4-21 3.4.11 Pressurizer Power Operated Relief Valves (PORVs).3.4-23 3.4.12 Low Temperature Overpressure Protection (LTOP) System.3.4-26 3.4.13 RCS Operational LEAKAGE.3.4-31 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage.3.4-33 3.4.15 RCS Leakage Detection Instrumentation.3.4-37 3.4.16 RCS Specific Activity.3.4-41 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS).3.5-1 3.5.1 Accumulators.3.5-1 3.5.2 ECCS - Operating.3.5-3 3.5.3 ECCS - Shutdown.3.5-6 3.5.4 Refueling Water Storage Tank (RWST).3.5-8 3.5.5 Seal Injection Flow.3.5-10 3.6 CONTAINMENT SYSTEMS.3.6-1 3.6.1 Containment.3.6-1 3.6.2 Containment Air Locks.3.6-2 3.6.3 Containment Isolation Valves.3.6-7 3.6.4 Containment Pressure.3.6-15 3.6.5 Containment Air Temperature.3.6-16 3.6..6 Containment Spray and Cooling Systems.3.6-17 3.6.7 Spray Additive System.3.6-20 Wolf Creek - Unit 1 ii Amendment No. 123,-134,

PAM Instrumentation 3.3.3 ACTIONS (continued) i.

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more Functions with C.1 Restore all but one 7 days two or more required channel to OPERABLE channels inoperable.

status.

D. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Table 3.3.3-1 Time of Condition C not for the channel.

met.

E.

As required by Required E.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action D.1 and referenced in Table 3.3.3-1.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F.

As required by Required F.1 Initiate action in Immediately Action D.1 and referenced accordance with in Table 3.3.3-1.

Specification 5.6.8.

Wolf Creek - Unit 1 3.3-38 Amendment No. 423,

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION D.1 I

1.

Neutron Flux

2.

Reactor Coolant System (RCS) Hot Leg Temperature (Wide Range)

3.

RCS Cold Leg Temperature (Wide Range)

4.

RCS Pressure (Wide Range)

5.

Reactor Vessel Water Level

6.

Containment Normal Sump Water Level

7.

Containment Pressure (Normal Range)

8.

Steam Line Pressure

9.

Containment Radiation Level (High Range)

10.

Not Used

11.

Pressurizer Water Level

12.

Steam Generator Water Level (Wide Range)

13.

Steam Generator Water Level (Narrow Range) 2 2

2 2

2 2

2 2 per steam generator 2

2 4

2 per steam generator 2 (a) 2(a) 2(a) 2(a) 4 2

E E

E E

F E

E E

F E

E E

I I

I I

14.

Core Exit Temperature - Quadrant I

15.

Core Exit Temperature - Quadrant 2

16.

Core Exit Temperature - Quadrant 3

17.

Core Exit Temperature - Quadrant 4

18.

Auxiliary Feedwater Flow Rate

19.

Refueling Water Storage Tank Level E

E E

E I

l E

E (a)

A channel consists of two core exit thermocouples (CETs).

Wolf Creek - Unit 1 3.3-40 Amendment No. 4213

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) (continued)

1.

NRC letter dated December 2, 1999, 'Wolf Creek Generating Station, Acceptance for Referencing of Pressure Temperature Limits Report (TAC No. MA4572)," and

2.

WCAP-1 4040-NP-A, 'Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves," January, 1996.

c.

The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

5.6.7 Not Used.

5.6.8 PAM Report When a report is required by Condition B or F of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.9 Not Used.

5.6.10 Steam Generator Tube Inspection Report

a.

Within 15 days following the completion of each inservice inspection of steam generator tubes, the number of tubes plugged in each steam generator shall be reported to the Commission.

b.

The complete results of the steam generator tube inservice inspection shall be submitted to the Commission in a report within 12 months following completion of the inspection. This Special Report shall include:

1)

Number and extent of tubes inspected, (continued)

Wolf Creek - Unit 1 5.0-30 Amendment No. 423,130,142,

Attachment IV to WO 04-0027 Page 1 of 10 ATTACHMENT IV TS BASES CHANGES (FOR INFORMATION ONLY)

Attachment IV to WO 04-0027 Page 2 of 10 TABLE OF CONTENTS B 3.3 INSTRUMENTATION (continued)

B 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation...................................

B 3.3-147 B 3.3.8 Emergency Exhaust System (EES)

Actuation Instrumentation

.B 3.3-156 B 3.4 REACTOR COOLANT SYSTEM (RCS).B 3.4.1-1 B 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits.B 3.4.1-1 B 3.4.2 RCS Minimum Temperature for Criticality.B 3.4.2-1 B 3.4.3 RCS Pressure and Temperature (PIT) Limits.B 3.4.3-1 B 3.4.4 RCS Loops - MODES 1 and 2.B 3.4.4-1 B 3.4.5 RCS Loops - MODE 3.B 3.4.5-1 B 3.4.6 RCS Loops - MODE 4.B 3.4.6-1 B 3.4.7 RCS Loops - MODE 5, Loops Filled.B 3.4.7-1 B 3.4.8 RCS Loops - MODE 5, Loops Not Filled.B 3.4.8-1 B 3.4.9 Pressurizer.B 3.4.9-1 B 3.4.10 Pressurizer Safety Valves.B 3.4.10-1 B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs).B 3.4.11-1 B 3.4.12 Low Temperature Overpressure Protection (LTOP)

System.B 3.4.12-1 B 3.4.13 RCS Operational LEAKAGE.B 3.4.13-1 B 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage.B 3.4.14-1 B 3.4.15 RCS Leakage Detection Instrumentation.B 3.4.15-1 B 3.4.16 RCS Specific Activity.B 3.4.16-1 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS).B 3.5.1-1 B 3.5.1 Accumulators.

B 3.5.1-1 B 3.5.2 ECCS - Operating.B 3.5.2-1 B 3.5.3 ECCS - Shutdown.B 3.5.3-1 B 3.5.4 Refueling Water Storage Tank (RWST).B 3.5.4-1 B 3.5.5 Seal Injection Flow.B 3.5.5-1 B 3.6 CONTAINMENT SYSTEMS.B 3.6.1-1 B 3.6.1 Containment B 3.6.1-1 B 3.6.2 Containment Air Locks B 3.6.2-1 B 3.6.3 Containment Isolation Valves B 3.6.3-1 B 3.6.4 Containment Pressure B 3.6.4-1 B 3.6.5 Containment Air Temperature B 3.6.5-1 B 3.6.6 Containment Spray and Cooling Systems

.B 3.6.6-1 B 3.6.7 Spray Additive Symtem B 3.6.7-1

~bin...7.7..6..7 Wolf Creek - Unit I ii Revision 0

Attachment IV to WO 04-0027 PAM Instrumentation Page 3 of 10 B 3.3.3 BASES LCO

8.

Steam Line Pressure (continued)

Steam Line Pressure is a Type A, Category I variable for event diagnosis, natural circulation, and RCP trip criteria. It is a variable for determining if a secondary pipe rupture has occurred. This indication is provided to aid the operator in determining the faulted steam generator and to verify natural circulation.

9.

Containment Radiation Level (High Range. GT-RIC-59, -60)

Containment Radiation Level is a Type A, Category I variable provided to monitor for the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans.

Containment radiation level is used to determine if a high energy line break (HELB) has occurred, and whether the event is inside or outside of containment.

10.

Con nment droeoncentro yrogi anly sar Cat~gr 1 va (bes prletoecA

}igh, yroge oncentra n cndition that reesn otn

11.

Pressurizer Water Level Pressurizer Water Level is a Type A, Category I variable used to determine whether to terminate Si, if still in progress, or to reinitiate SI if it has been stopped. Knowledge of pressurizer water level is also used to verify the unit conditions necessary to establish natural circulation in the RCS and to verify that the unit is maintained in a safe shutdown condition.

12.

Steam Generator Water Level (Wide Range)

SG Water Level (Wide Range) is a Category I variable provided to monitor SG dryout and as a criterion for establishing feed and bleed cooling of the RCS. The wide range level indicator for each steam generator is located in the main control room. Wide range steam generator level measurement meets the intent of the single failure criterion for Category 1 variables by virtue of independent diverse variables. In the emergency procedures, auxiliary feedwater (AFW) flow, reactor coolant pressure, and reactor coolant temperature indications are diverse variables which are Wolf Creek - Unit 1 B 3.3.3-7 Revision 8 1

Attachment IV to WO 04-0027 PAM Instrumentation Page 4 of 10 B 3.3.3 BASES ACTIONS C.1 (continued)

(continued) qualification requirements applied to the PAM instrumentation. Therefore, requiring restoration of all but one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an acciden occur Co tiorC is difi y a ote~hft e(ohytbg,pra yehape lss ondion ies er

)^topera

e. RqedcirD1 re ires repigotydrog

/

r nlrcailt PRBLE Saus witn7 rs The2 hou

) Crfnleiorjm isrgonabl as d o, he unli ly evenha,5C/

Condition plies when the Required Action and associated Completion Time of Condition C not met. Required Action quires entering the appropriate Condition referenced in Table 3.. -1 for the channel immediately. The applicable Condition referenced in the Table is Function dependent. Each time an inoperable channel has not met any Required Acti f Condition C X and the associated Completion Time to) has expired, Condition is entered for that channel and provides for transfer to the appropriate subsequent Condition.

If the Required Action and associated Completion Time of Conditions Cla isD ~ 3 not met and Table 3.3.3-1 directs entry into Conditionphe unit must be brought to a MODE where the requirements of this LCO do not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Wolf Creek - Unit 1 B 3.3.3-12 Revision 8 1

Attachment IV to WO 04-0027 PAM Instrumentation Page 5 of 1B 3.3.3 BASES ACTIONS (continued)

Alternate means of monitoring Reactor Vessel Water Level and Containment Area Radiation have been developed. These alternate means may be temporarily used if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. If these alternate means are used, the Required Action is not to shut down the unit but rather to follow the directions of Specification 5.6.8, in the Administrative Controls section of the TS. Monitoring the core exit thermocouples, pressurizer level indication (BB-LI-0459A, -0460A, or -0461) and RCS subcooling monitor indication (BB-TI-1390A or B) provide an alternate means for RVLIS. These 3 parameters provide diverse information to verify there is adequate core cooling. When Containment Radiation Level (High Range) monitors are inoperable, portable survey equipment with the capability to detect gamma radiation over the range I E-03 to 1 E04 provides an alternate means (Ref. 5).

SURVEILLANCE A Note has been added to the SR Table to clarify that SR 3.3.3.1 REQUIREMENTS and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1.

SR 3.3.3.1 Performance of the CHANNEL CHECK once every 31 days ensures that a gross instrumentation failure has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation should be compared to similar unit instruments located throughout the unit.

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.

Wolf Creek - Unit I B 3.3.3-13 Revision 8 l

Attachment IV to WO 04-0027

/

Page 6 of 10 Hydra en Recombine B 3.6

/B 3.6 CO AIMENT S TMs///

B 3.

Hydroge Re pmbiners///

BACKGRO D

The functic of the hydrogen rec biners is to elimina te potential breach o containment due to ydrogen oxygen re tion.

Per CFR 50.44, "Stand ds for Combustible as Control Systems in Li t-Water-Cooled Rea ors" (Ref. 1), and G 41, "Containment mosphere Cleanup" ef. 2), hydrogen re mbiners are required t reduce the hydroge oncentration in the ntainment following a ss o coolant accident (

CA) or steam line boak (SLB). The recom ers accomplish this recombining hydrogen and oxygen to form ater vapor. The va or remains in contai36ent, thus eliminating y discharg to the enviro ment. The hydroge,"ecombiners are manu y initiated since flam able limits would note reached until sever days after a Design sis Accident (DBA)./

Tw 00% capacity indep dent hydrogen recoim er systems are pr vided. Each consist of controls located in th control room, a powe upply and a recombi

r. Recombination is a omplished by heating hydrogen air mixtur above 11 500F. The reeiting water vapor and discharge gases e cooled prior to discha e from the recombine,< A single recombi r is capable of maintain g the hydrogen conce ration containment low the 4.0 volume per nt (via) flammability iit.

Two

/recombineare provided to meet th requirement for redu ancy and independ ce. Each recombiner i powered from a sepa te Engineere Safety atures bus, and is prov ed with a separate poper panel and contr panel.

t /4PPLICABLE

^714he hydrogen recombinsprovide for the capality of controlling th SAFETY ANALYS bulk hydrogen concen ation in containment t ess than the lower flammable concentration of 4.0 v/o followin DBA. This contro ould prevent a containrpent wide hydrogen bu thus ensuring the essure and temperaturesign limits are not e eeded. The limitin BA relative to hyd gen generation is a LCA.

Hydrogen ay accumulate in co nment following a OCA as a result of:

a.

A metal steam reacti between the zircoIium fuel rod claddin i

the reactor coolant,

b.

Radiolytic dec position of water i the Reactor Coolan ystem (RCS) and t containment sum Wolf Creek - Unit I B 3.6.8-1 Revision 0

Attachment IV to WO 04-0027 Page 7 of Wolf Creek - Unit 1 B 3.6.8-2 Revision 0

Attachment IV to WO 04-0027 Hydrogen ners Page 8of10fl B 3.6.8 ABASES

////

APPLI BILITY I

ODES 5 and 6, th pobability and conse ces of a LOCA are low, (cor nued)

)det tepesure, d temperature limitatid in these MODES.

//

Therefore, hydro recombiners are n quired in these MODES.

/

' CIONS /A.1

/

With e containment hydrog recombiner inoperable, the' operable rec biner must be restor to OPERABLE status within days. In this c

dition, the remaining ERABLE hydrogen recomb er is adequate to erform the hydrogen ntrol function. However, th verall reliability is reduced because a gle failure in the OPERAB recombiner could result in reduced drogen control capability.

e 30 day Completion Time is based p fthe availability of the other drogen recombiner, the low probabilof a LOCA or SLB occurrin (that would generate an amount of ydrogen that exceeds the inability limit), and the amou of time ailable after a LOCA or SLX(should one occur) for operat actio o prevent hydrogen accu ation from exceeding the fla ability

/

~~lim,>

equired Action A.1 has en modified by a Note that stas the provisions of LCO 3.0.4re not applicable. As a resul MODE change is allowed when one combiner is inoperable. Thi lowance is based on the availability the other hydrogen recombi

, the low probability of a LOCA or SL ccurring (that would generat n amount of hydrogen that exceeds e flammability limit), and the ount of time available after a LOCA o LB for operator action to pre nt hydrogen accumulation fro eding the flammability limit.

With two hydrogen reco ners inoperable, the ability perform the hydrogen control fun n via alternate capabilities st be verified by administrative mea within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The alternat ydrogen control capabilities are p vided by the containment Hrn rogen Purge System.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Co pletion Time allows a reaso ble period of time to ver that a loss ydrogen control function d s not exist. Both the iniM verificatisand all subsequent verificag ns may be performed a n

admin rative check by examining I s or other information t etermine the ailability of the alternate hy ogen control system. It oes not mean t

erform the Surveillances n ded to demonstrate OPE BILITY of the alternate hydrogen control tem. If the ability to pe rm the hydrogen control function is maint ed, continued operatio permitted with tw hydrogen recombinere operable for up to 7 da Nr.

Seven days is a reasonable time to ow two hydrogen reco iners to be inopera e because the hyd gen control function is intained and beca e of the low probabilit'f the occurrence of a L A that would gene te hydrogen mlimi Wolf Creek - Unit I B 3.6.8-3 Revision 0

Attachment IV to WO 04-0027 Kyd n

Page9 of10

~~Hdro Recombiners Page 9 of 10 B 3.6.8 BASES ACTI S

C (c

tinued)

If the inoperable drogen recombiner(s cannot be restored to OPERABLE st s within the required ompletion Time, the pI t must be brought to a DE in which the LC does not apply. To ac eve this status, the ant must be brought at least MODE 3 withi hours. The

/

Completio Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> iOs reaonable, based on oprtn experiene to reach MODE 3Afom full power conditios ina rderly

/mar and without chall 7ng plant systems./

SgEILLANCE

,jR 3.6.8.1///

EQUIREMENTS Performance of a ystem functional test f each hydrogen recombin ensures the rec biners are operation and can attain and sustaii he temperature cessary for hydrogen combination. In particular his SR verifies tha e minimum heater shath temperature increases

/ 211500 5 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

Oper ng experience has s wn that these components sually pass the Su Hellance when perfor d at the 18 month Freque

. Therefore, the F quency was conclud to be acceptable from a r ability standpoint.

/ SR 3.6.8.2

///

This SR ensu there are no physical pr lems that could affect recombinersuperation. Since the recomn ners are mechanically p1 sive, they are t subject to mechanical fai re. The only credible fail e involve ass of power, blockage ofge internal flow, missile i act, etc.

A vJ i inspection is sufficient determine abnormal co itions (i.e.,

I se wiring or structural con ctions, deposits of forei materials, etc.)

at could cause such failu s. The 18 month Freque cy for this SR wa developed considering t Incidence of hydrogen rombiners failing t SR in the past is low.

\\

/

S~SR 3.6.8.3

///

This SR, wh is performed following efunctional test o R 3.6.8.1, requires p ormance of a resistanco ground test for ch heater phase to ensur that there are no detect le grounds in any eater phase. Th is acc plished by verifying tha he resistance to und for any hear pha e is 2 10,000 ohms.

he 18 month Frequency rthis Surveillanc as developed nsidering the incidence of hydrog recombiners fail g the SR in the st is low.

Wolf Creek - Unit 1 B 3.6.8-4 Revision 0

Attachment IV to WO 04-0027 Page 10 of 10 Wolf Creek - Unit 1 B 3.6.8-5 Revision 0

Attachment V to Wa 04-0027 Attachment V to WO 04-0027 Page 1 of 1 LIST OF COMMITMENTS The following table identifies those actions committed to by WCNOC in this document. 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 Due DatelEvent The proposed changes to the WCGS Technical Specifications Within 90 days of will be implemented within 90 days of NRC approval. Revision NRC approval.

to the TS Bases will be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment.

WCNOC has verified that a hydrogen monitoring system Within 90 days of capable of diagnosing beyond design-basis accidents is NRC approval.

installed at WCGS and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Technical Requirements Manual. This regulatory commitment will be implemented within 90 days of NRC approval of this amendment request.