Letter Sequence Request |
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TAC:MD4840, Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications (Approved, Closed) |
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MONTHYEARET 07-0040, Response to Request for Additional Information Relating to Replacement of the Main Steam and Feedwater Isolation Valves and Controls2007-09-12012 September 2007 Response to Request for Additional Information Relating to Replacement of the Main Steam and Feedwater Isolation Valves and Controls Project stage: Response to RAI ET 07-0050, Response to Request for Additional Information Relating to Replacement of the Main Steam and Feedwater Isolation Valves and Controls2007-10-16016 October 2007 Response to Request for Additional Information Relating to Replacement of the Main Steam and Feedwater Isolation Valves and Controls Project stage: Response to RAI ET 08-0005, Response to Request for Additional Information Relating to Replacement of the Main Steam and Feedwater Isolation Valves and Controls2008-01-18018 January 2008 Response to Request for Additional Information Relating to Replacement of the Main Steam and Feedwater Isolation Valves and Controls Project stage: Response to RAI ET 08-0011, Revisions to Proposed Changes to Technical Specification 3.7.3, Main Feedwater Isolation Valves (Mfivs)2008-02-26026 February 2008 Revisions to Proposed Changes to Technical Specification 3.7.3, Main Feedwater Isolation Valves (Mfivs) Project stage: Request ML0804500042008-02-29029 February 2008 Request for Withholding Information from Public Disclosure (10/8/2008 Affidavit Executed by J. A. Gresham, Westinghouse Electric Company LLC) (Tac No. MD4840) Project stage: Withholding Request Acceptance ML0804500102008-02-29029 February 2008 Request for Withholding Information from Public Disclosure (1/7/2008 Affidavit Executed by J. A. Gresham, Westinghouse Electric Company LLC) (Tac MD4840) Project stage: Withholding Request Acceptance ML0806502192008-03-21021 March 2008 License Amendment 176 Replacement of Main Stream and Feedwater Isolation Valves Project stage: Approval ML0803701172008-04-0303 April 2008 Issuance of License Amendment No. 177, Revise TS 3.3.2, ESFAS and TS 3.7.3, Main Feedwater Isolation Valves by Addition of Main Feedwater Regulating Valves and Associated Bypass Valves Project stage: Approval ML0803701212008-04-0303 April 2008 Tech Spec Pages for Amendment No. 177, Revise TS 3.3.2, ESFAS and TS 3.7.3, Main Feedwater Isolation Valves by Addition of Main Feedwater Regulating Valves and Associated Bypass Valves Project stage: Other ML0811201492008-04-29029 April 2008 Corrected Technical Specification Pages, Amendment No. 177 Revision to Technical Specification 3.7.3, Main Feedwater Isolation Valves, to Add Main Feedwater Regulating Valves and MFRV Bypass Valves Project stage: Other ML0810702772008-04-29029 April 2008 Correction to Amendment No. 177 Revision to Technical Specification 3.7.3, Main Feedwater Isolation Valves, to Add Main Feedwater Regulating Valves (MFRV) and MFRV Bypass Valves Project stage: Other 2008-02-26
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Category:Letter type:ET
MONTHYEARET 23-0006, CFR 50.55a Request Number CI3R-01 for the Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded Post-Tensioning System Components2023-05-17017 May 2023 CFR 50.55a Request Number CI3R-01 for the Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded Post-Tensioning System Components ET 23-0005, 10 CFR 50.55a Request Number I4R-08 for the Fourth Inservice Inspection Program Interval, Relief for Extension of Follow Up Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peen2023-03-16016 March 2023 10 CFR 50.55a Request Number I4R-08 for the Fourth Inservice Inspection Program Interval, Relief for Extension of Follow Up Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened ET 23-0003, License Amendment Request (LAR) for Removal of the Power Range Neutron Flux Rate - High Negative Rate Trip Function from Technical Specifications2023-03-0101 March 2023 License Amendment Request (LAR) for Removal of the Power Range Neutron Flux Rate - High Negative Rate Trip Function from Technical Specifications ET 23-0002, Supplement to License Amendment Request to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections2023-02-0707 February 2023 Supplement to License Amendment Request to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ET 23-0004, Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements2023-01-26026 January 2023 Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements ET 22-0006, Operating Corp. - Application to Revise Technical Specifications to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections2022-12-0101 December 2022 Operating Corp. - Application to Revise Technical Specifications to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ET 22-0010, License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements2022-08-0202 August 2022 License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements ET 22-0012, Supplement to License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating2022-07-12012 July 2022 Supplement to License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating ET 22-0011, Withdrawal of 10 CFR 50.55a Request I4R-08, Relief for Extension of Follow-up Examination and Visual Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surface2022-05-31031 May 2022 Withdrawal of 10 CFR 50.55a Request I4R-08, Relief for Extension of Follow-up Examination and Visual Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surface ET 22-0005, Response to Request for Additional Information Regarding License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating2022-04-13013 April 2022 Response to Request for Additional Information Regarding License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating ET 22-0003, CFR 50.55a Request I4R-09 for the Fourth Inservice Inspection Program Interval, Relief from Examination of Reactor Vessel Flange Threads2022-04-0606 April 2022 CFR 50.55a Request I4R-09 for the Fourth Inservice Inspection Program Interval, Relief from Examination of Reactor Vessel Flange Threads ET 22-0002, Operating Corp 10 CFR 50.55a Request Number I4R-08 for the Fourth Inservice Inspection Program Interval, Relief for Extension of Follow Up Examination and Visual Examination Requirements for Reactor Pressure Vessel Head .2022-04-0404 April 2022 Operating Corp 10 CFR 50.55a Request Number I4R-08 for the Fourth Inservice Inspection Program Interval, Relief for Extension of Follow Up Examination and Visual Examination Requirements for Reactor Pressure Vessel Head . ET 22-0004, Operating Corp - Response to Request for Confirmation of Information (RCI) Regarding Steam Generator Tube Inspection Report2022-03-15015 March 2022 Operating Corp - Response to Request for Confirmation of Information (RCI) Regarding Steam Generator Tube Inspection Report ET 22-0001, Removal of the Table of Contents from the Technical Specifications2022-01-12012 January 2022 Removal of the Table of Contents from the Technical Specifications ET 21-0017, Response to Request for Additional Information Regarding License Amendment Request - Revision to Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation2021-12-22022 December 2021 Response to Request for Additional Information Regarding License Amendment Request - Revision to Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ET 21-0009, Results of the Steam Generator Tube Inservice Inspection During the 24th Refueling Outage2021-11-0101 November 2021 Results of the Steam Generator Tube Inservice Inspection During the 24th Refueling Outage ET 21-0015, Withdrawal of License Amendment Request for a Risk-Informed Resolution to GSI-1912021-10-20020 October 2021 Withdrawal of License Amendment Request for a Risk-Informed Resolution to GSI-191 ET 21-0012, Supplement to License Amendment Request for a Risk-Informed Resolution to GSI-1912021-10-11011 October 2021 Supplement to License Amendment Request for a Risk-Informed Resolution to GSI-191 ET 21-0004, License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating2021-09-29029 September 2021 License Amendment Request - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating ET 21-0010, License Amendment Request - Revision to Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation2021-09-29029 September 2021 License Amendment Request - Revision to Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ET 21-0005, Operating Corp., License Amendment Request for a Risk-Informed Resolution to GSI-1912021-08-12012 August 2021 Operating Corp., License Amendment Request for a Risk-Informed Resolution to GSI-191 ET 20-0013, Response to Request for Additional Information Re Application for Technical Specification Change Re Risk-Informed Justification for Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program (TSTF-415)2020-10-26026 October 2020 Response to Request for Additional Information Re Application for Technical Specification Change Re Risk-Informed Justification for Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program (TSTF-415) ET 20-0011, Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2020-10-0101 October 2020 Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI ET 20-0007, License Amendment Request for Replacement of Engineered Safety Features Transformers with New Transformers That Have Active Automatic Load Tap Changers2020-06-0808 June 2020 License Amendment Request for Replacement of Engineered Safety Features Transformers with New Transformers That Have Active Automatic Load Tap Changers ET 20-0008, Operating Corporation Update for Full Implementation of Open Phase Detection System2020-05-20020 May 2020 Operating Corporation Update for Full Implementation of Open Phase Detection System ET 20-0004, Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425)2020-04-27027 April 2020 Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425) ET 20-0002, Response to Request for Additional Information Regarding Utilizing Code Case N-666-1, Weld Overlay of Class 1, 2, and 3 Socket Welded Connections, Section XI, Division 12020-01-29029 January 2020 Response to Request for Additional Information Regarding Utilizing Code Case N-666-1, Weld Overlay of Class 1, 2, and 3 Socket Welded Connections, Section XI, Division 1 ET 19-0021, Errata for Supplemental Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation2019-12-0909 December 2019 Errata for Supplemental Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation ET 19-0020, Supplemental Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation2019-11-13013 November 2019 Supplemental Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation ET 19-0019, Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.2019-09-10010 September 2019 Response to Request for Additional Information Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation. ET 19-0018, Supplement to License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.2019-08-22022 August 2019 Supplement to License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation. ET 19-0014, lnserv1ce Inspection (ISI) Program Relief Request Number 14R-07, to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, D1v1s1on 12019-08-15015 August 2019 lnserv1ce Inspection (ISI) Program Relief Request Number 14R-07, to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, D1v1s1on 1 ET 19-0002, License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation.2019-03-18018 March 2019 License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation. ET 19-0008, Response to Request for Additional Information Related to Thermal Conductivity Degradation for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption.2019-03-0505 March 2019 Response to Request for Additional Information Related to Thermal Conductivity Degradation for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption. ET 19-0003, License Amendment Request to Revise Technical Specification 3.6.3 and Surveillance Requirement 3.6.3.1 to Remove Use of a Blind Flange2019-02-25025 February 2019 License Amendment Request to Revise Technical Specification 3.6.3 and Surveillance Requirement 3.6.3.1 to Remove Use of a Blind Flange ET 19-0001, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 42019-01-23023 January 2019 Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4 ET 18-0032, Operating Corporation Change of Date for Full Implementation of Open Phase Detection System2018-12-0707 December 2018 Operating Corporation Change of Date for Full Implementation of Open Phase Detection System ET 18-0035, Operating Corp., Supplemental Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-12-0606 December 2018 Operating Corp., Supplemental Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term ET 18-0029, (WCGS) - Results of the Twenty First Steam Generator Tube Inservice Inspection2018-10-31031 October 2018 (WCGS) - Results of the Twenty First Steam Generator Tube Inservice Inspection ET 18-0018, Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-06-19019 June 2018 Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term ET 18-0016, Response to Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools Request for Supplemental Information2018-05-29029 May 2018 Response to Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools Request for Supplemental Information ET 18-0014, Response to Request for Additional Information Regarding the License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.2018-05-29029 May 2018 Response to Request for Additional Information Regarding the License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System. ET 18-0013, Relief Request Number I4R-06, Request for Relief from ASME Code Case N-729-4 for Reactor Vessel Head Penetration Nozzle Weld2018-05-0202 May 2018 Relief Request Number I4R-06, Request for Relief from ASME Code Case N-729-4 for Reactor Vessel Head Penetration Nozzle Weld ET 18-0011, (WCGS) - Guarantee of Payment of Deferred Premiums2018-04-30030 April 2018 (WCGS) - Guarantee of Payment of Deferred Premiums ET 18-0012, Operating Corp., Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-04-19019 April 2018 Operating Corp., Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term ET 18-0010, Financial Protection Levels2018-03-29029 March 2018 Financial Protection Levels ET 18-0007, Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.2018-02-15015 February 2018 Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System. ET 18-0005, Withdrawal of License Amendment Request for Revision to the Emergency Plan2018-02-0505 February 2018 Withdrawal of License Amendment Request for Revision to the Emergency Plan ET 18-0004, Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-01-29029 January 2018 Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term ET 17-0025, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term2017-11-14014 November 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term 2023-05-17
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Text
W0LF CREEK NUCLEAR OPERATING CORPORATION Terry J. Garrett February 26, 2008 Vice President, Engineering ET 08-0011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Reference:
Letter ET 07-0004, dated March 14, 2007, from T. J. Garrett, WCNOC, to USNRC
Subject:
Docket No. 50-482: Revisions to Proposed Changes to Technical Specification 3.7.3, "Main Feedwater Isolation Valves (MFIVs)"
Gentlemen:
The Reference provided a license amendment request that proposed revisions to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," and .TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs)," based on a planned modification to replace the MSIVs and associated actuators, MFIVs and associated actuators, and replacement of the Main Steam and Feedwater Isolation System (MSFIS) controls. The Reference included changes to TS 3.7.3 to incorporate into the technical specifications, requirements associated- to .the Main Feedwater Regulation Valves (MFRVs) and MFRV bypass valves. The MFRVs and MFRV bypass valves are added to TS 3.7.3 as these valves are credited in the accident analyses to provide a backup to the MFIVs for a potential failure of an MFIV to close.
Wolf Creek Nuclear Operating Corporation (WCNOC) personnel recently identified that the changes proposed in the Reference to the Applicability in TS 3.7.3 did not accurately reflect the design conditions when the Limiting Condition for Operation (LCO) should be applicable.
Attachment I provides information regarding the additional changes to TS 3.7.3 LCO and Applicability. Attachment II provides revised markups of affected TS 3.7.3 pages. Attachment III provides revised markups of affected TS 3.7.3 Bases pages. Themarked-up TS Bases pages are provided for information only.
The revisions to the proposed changes to TS 3.7.3 and, information provided in the Attachments do not impact the conclusions of the No, Significant Hazards Consideration provided in Reference 1. In accordance with 10 CFR 50.91, a-copy of this submittal is being provided to the designated Kansas State official.
P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HC/VET tAQ
ET 08-0011 Page 2 of 3 This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr. Richard Flannigan at (620) 364-4117.
Sincerely, Terry J. Garrett TJG/rlt Attachment II Additional Changes to TS 3.7.3 IIl Revised Markups of TS 3.7.3 Revised TS Bases Markups (for information only) cc: E. E. Collins (NRC), w/a T. A. Conley (KDHE), w/a J. N. Donohew (NRC), w/a V. G. Gaddy (NRC), w/a B. K. Singal (NRC), w/a Senior Resident Inspector (NRC), w/a
ET 08-0011 Page 3 of 3 STATE OF KANSAS )
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.
TerryJ eesarrett Vice Piesident Engineering SUBSCRIBED and sworn to before me this2LpLday of tJo. , 2008.
rl GAYLE SHEPH EARD Notar ublic Notary Public - State cf Kansas My Appt. Expires /
Expiration Date _______2__
Attachment I to ET 08-0011 Page 1 of 3 Additional Changes to TS 3.7.3 Wolf Creek Nuclear Operation Corporation (WCNOC) letter ET 07-0004, dated March 14, 2007, provided a license amendment request that proposed revisions to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," and TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs),"
based on a planned modification to replace the MSIVs and associated actuators, MFIVs and associated actuators, and replacement of the Main Steam and Feedwater Isolation System (MSFIS) controls.
WCNOC proposed changes to TS 3.7.3 to incorporate into the technical specifications, requirements associated to the Main Feedwater Regulation Valves (MFRVs) and MFRV bypass valves. The MFRVs and MFRV bypass valves are added to TS 3.7.3 as these valves are credited in the accident analyses to provide a backup to the MFIVs for a potential failure of an MFIV to close. This change included revising the Limiting Condition for Operation (LCO) and Applicability to address the addition of the MFRVs and MFRV baypass valves and the valve specific configurations. Specifically, WCNOC proposed the following wording for the Applicability:
LCO 3.7.3 Four MFIVs and their associated actuator trains, four MFRVs and MFRV bypass valves shall be OPERABLE.
APPLICABILITY: MODE 1 MODES 2 and 3, except when:
- a. MFIV is closed and de-activated; or
- b. MFRV is closed and de-activated or closed and isolated by a closed manual valve; or
- c. MFRV bypass valve is closed and de-activated, or closed and isolated by a closed manual valve, or isolated by two closed manual valves.
WCNOC personnel recently identified that the changes proposed in letter ET 07-0004 to the Limiting Condition for Operation (LCO) and Applicability in TS 3.7.3 did not accurately reflect the design conditions when the LCO should be applicable. Specifically, it was determined that the proposed wording could allow the valves on different feedwater lines to be closed and result in the potential to not properly isolate the feedwater line. Additionally, the proposed wording would not result in isolation of feedwater flow if only the MFRV (and associated manual valve) is closed or the MFRV bypass valve (and associated manual valves) is closed. Both the MFRV and MFRV bypass valve in the same feedwater line must be closed to provide isolation of feedwater flow to the steam generator.
Attachment I to ET 08-0011 Page 2 of 3 Based upon the above, WCNOC is proposing to revise the LCO and Applicability as follows:
LCO 3.7.3 Each MFIV and its associated actuator trains, MFRV and MFRV bypass valve for the four main feedwater lines shall be OPERABLE.
APPLICABILITY: MODE 1 MODES 2 and 3, except for each affected main feedwater line when:
- a. The MFIV is closed and deactivated; or
- b. The MFRV is closed and deactivated or closed and isolated by a closed manual valve; and the MFRV bypass valve is either closed and deactivated, closed and isolated by a closed manual valve, or isolated by two closed manual valves.
The proposed revision of the LCO and Applicability are revised to reflect the appropriate design conditions for when the LCO should be applicable. Attachment II provides revised markups of affected TS 3.7.3 pages. Specifically, pages 2 and 3 of Attachment II to this letter replaces page 9 of 12 of Attachment II to letter ET 07-0004. Attachment III provides revised markups of affected TS 3.7.3 Bases pages. Specifically, pages 2 and 3 of Attachment III to this letter replace page 37 of 46 and page 38 of 46 of Attachment IV to letter ET 07-0004. The proposed changes to TS 3.7.3 do not affect the changes provided in letter ET 07-0052, dated 12/18/07, to footnote (j) of TS Table 3.3.2-1.
Use of Manual Isolation Valves Letter ET 07-0004 proposed changes to the TSs that would allow the use of manual isolation valves. Provided below is information regarding the manual valves specified in the proposed TSs.
Valves AEV0076, 0078, 0080, and 0082 - are the manual isolation valves associated with the MFRV (see attached P&ID). These valves are 14 inch Crane gate valves. The valves are carbon steel with a pressure rating of 900 lbs.
Valves AEV0257, 0258, 0259, 0260, 0261, 0262, 0263, and 0264 - are the manual isolation valves associated with the MFRV bypass valves. These valves are 6 inch Crane gate valves.
The valves are carbon steel with a pressure rating of 900 lbs.
These valves were purchased under Specification No. 16577-M-245, "Technical Specification for 600- Through 1500-pound Critical Check, Gate and Globe Valves 2-1/2 inches and LARGER
- Carbon Steel to ANSI B31.1 for the Wolf Creek Generating Station," which provided design requirements that the valves and their actuator have a design life of 40 years at the specified environmental and service conditions. The environmental conditions are that the valves are exposed to ambient conditions of 1) temperature of 600 to 120 0 F, 2) atmospheric pressure, and
- 3) 100% relative humidity. The design service conditions are that the contained fluid be steam and feedwater. Manual gate valves are typically used for system isolation when automatic isolation is not required.
Attachment I to ET 08-0011 Page 3 of 3 The use of a closed manual isolation valve is consistent with the Improved Standard Technical Specification (ISTS) 3.7.3 and Table 3.3.2-1. The TS 3.7.3 Bases, Applicability, states, in part:
'When the valves are closed and de-activated or isolated by a closed manual valve, they are already performing their safety function."
1to ET 08-001 1 Page 1 of 3 Revised Markups of TS 3.7.3
Attachment II to ET 08-00111 Page 2 of 3 3.7.3 3.7 PLANT SYSTEMS .r-szv "ByV ,-SS V'%\I ,s4 3.7.3 Main Feedwater Isolation Valves (MFIVs)
LCO 3.7.3 Fo MFI'y,%nd t ir ass~oratedA'ctua~rtrýi41s sh~alf be/,1ýRABWk.
APPLICABILITY:
ACTIONS .1 CONDITION REQUIRED ACTION COMPLETION TIME A. One MFIV actuator train A.1 Restore MFIV actuator 7 days inoperable, train to OPERABLE status.
B. Two MFIV actuator trains B.1 Restore one MFIV 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for different actuator train to MFIVs when the inoperable OPERABLE status.
actuator trains are not in the same separation group.
C. Two MFIV actuator trains C.1 Restore one MFIV 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inoperable when the actuator train to inoperable actuator trains OPERABLE status.
are in the same separation group.
D. Two actuator trains for one D.1 Declare the affected MFIV Immediately MFIV inoperable. inoperable.
(continued)
Wolf Creek - Unit 1 3.7-8 Amendment No. 12-3, 171
Attachment II to ET 08-0011 Page 3 of 3 INSERT 3.7-8A Each MFIV and its associated actuator trains, MFRV and MFRV bypass valve for the four main feedwater lines shall be OPERABLE.
INSERT 3.7-8B MODE 1 MODES 2 and 3, except for each affected main feedwater line when:
- a. The MFIV is closed and deactivated; or
- b. The MFRV is closed and deactivated or closed and isolated by a closed manual valve; and the MFRV bypass valve is either closed and deactivated, closed and isolated by a closed manual valve, or isolated by two closed manual valves.
Attachment III to ET 08-0011 Page 1 of 3 Revised TS Bases Changes (for information only)
Attachment III to ET 08-0011 Ca~yv MFR\s MrIA tiFi'v 13R-vsVai Page 2 of 3 MFIVs B3.7.3 (ine& &55ock'akeýA O.cLAaMof -+ratn,
' WAI BASES LCO This LCO ensures that the MFIVsY ilsolate MFW flow to the steam generators, following an FWLB or main steam line break. .xaW'-
will also isolate the nonsafety related portions from the safety related eachc- MF=V a.nA its a&scri&?reA " A--.
w*MF zia e.
portions of the system.
a LtA&tor -rq i mc5- MFg.V o~v~cvL MFR.V byp~se. VAlve 16- t~eA:UX' This LCO requires that o MF ls and lHeir ap-gociat actu For trai-. be AE.COPT,46 MFI s are,onid RAB wh ie isola' n OPER^15LE . I kiittes ae witbn limi and they clo* on isola 'on acu'ation srgnal.
"'-An MFIV actuator train is considered OPERABLE when it is capable of (j)closing the associated MFIV on demand and within the required isolation time. "hjs'includps havingadequAte ac mulatoepressye to' sup-jl6rt fst-cloq6 re of tJe MF IVithin t* req e*d isopion tipre andy Failure to meet the LCO requirements can result in additional mass and energy being released to containment following an SLB or FWLB inside containment. A feedwater isolation signal on high steam generator level is relied on to terminate an excess feedwater flow event, and failure to meet the LCO may result in the introduction of water into the main steam lines.
APPLICABILITY The MFIVsmust be OPERABLE whenever there is significant mass and energy in the Reactor Coolant System and steam generators. In
, tr.V KVS5 VV .-MODES 1, 2, and 3, the MFIV .are required to be OPERABLE to perform 6o..,5 yA1.e-., their isolation function and limit the amount of available fluid that could be 9 ýý;6 9 ýadded to containment in the case of a secondary system pipe break inside containment. When the valves are closed, they are already performing their safety function. The MFIV actuator trains must be OPERABLE in MODES 1, 2, and 3 to support operation of the MFIV.
In MODES 4, 5, and 6, steam generator energy is low. Therefore, the MFIVscan be closed since MFW is not required.
ACTIONS The LCO specifies OPERABILITY requirements for the MFIVs as well as for their associated actuator train *. The Conditions and Required Actions for TS 3.7.3 separately address inoperability of the MFIV actuator trains and inoperability of the MFIVs themselves.
for Wolf Creek - Unit 1 B 3.7.3-3 Revision 130
Attachment III to ET 08-0011 Page 3 of 3 INSERT B 3.7.3-3a The MFIVs are considered OPERABLE when isolation times are within the limits of Figure B 3.7.3-1 when given a close signal and they are capable of closing on an isolation actuation signal. The MFRVs and MFRV bypass valves are considered OPERABLE when isolation times are < 15 seconds when given an isolation actuation signal and they are capable of closing on an isolation actuation signal. For the MFRVs and the MFRV bypass valves, the LCO requires only that the trip close function is OPERABLE.
INSERT B 3.7.3-3b Feedwater is supplied to the four steam generators by four feedwater lines. One MFIV is installed in each of the four feedwater lines downstream of the MFRV and MFRV bypass valve.
When the feedwater line that feeds the steam generator is isolated, the safety function is being met. In MODES 2 and 3, a MFIV, MFRV and MFRV bypass valve on their associated main feedwater line are not required to meet the requirement of this LCO where the valve(s) are assured of performing their safety function as follows:
- a. When the MFIV is closed and de-activated, it is performing is safety function. Requiring the valve closed and de-activated provides assurance that it is performing its safety function. The MFIV is a system-medium actuated valve, opened by system pressure acting on the lower piston chamber, closed by the weight of the valve internals and system pressure acting on the upper piston chamber. To de-activate the MFIV, the electrical power sources are removed from the actuation solenoids and a drain or vent path is available from the lower piston chamber.
- b. Isolation of the feedwater line is accomplished by isolation of the MFRV and MFRV bypass valve. When the MFRV is closed and de-activated or is closed and isolated by a closed manual valve, it is performing its safety function. Requiring the valve closed and de-activated provides dual assurance that it is performing its safety function. When the valve is de-activated, power is removed from the actuation solenoids on the valves.
Requiring the valve closed and isolated by a closed manual valve also provides dual assurance that it is performing its safety function. When the MFRV bypass valve is closed and de-activated, or is closed and isolated by a closed manual valve, or is isolated by two closed manual valves, it is performing its safety function. Requiring the valve closed and de-activated provides dual assurance that it is performing its safety function. When the valve is de-activated, power is removed from the actuation solenoids on the valves. Requiring the valve closed and isolated by a closed manual valve also provides dual assurance that it is performing its safety function. Finally, there is assurance that the safety function is being performed when the MFRV bypass valve is isolated by two closed manual valves.