Text

License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements - Volume Control Tank Outlet Valves
	ML12299A312
Person / Time
Site:	Wolf Creek
Issue date:	10/18/2012
From:	Broschak J; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ET 12-0022
	Download: ML12299A312 (23)
	v • d • e

V~LFCREEK NUCLEAR OPERATING CORPORATION John P. Broschak Vice President Engineering October 18, 2012 ET 12-0022 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements - Volume Control Tank Outlet Valves Gentlemen:

Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," and 10 CFR 50.91, "Notice for public comment; State consultation," Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to the Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS). This license amendment request is seeking approval by the Commission, pursuant to License Condition 2.C(5), to make changes to the approved fire protection program as described in the Updated Safety Analysis Report (USAR). Specifically, a deviation from the separation requirements of 10 CFR 50, Appendix R, Section III.G.2, as documented in Appendix 9.5E of the WCGS Updated Safety Analysis Report (USAR), is requested for the volume control tank outlet valves (BGLCV0112B and BGLCV0112C).

Attachment I provides the evaluation and justification for the proposed license amendment.

Attachment II provides a markup of License Condition 2.C(5) reflecting the issuance of an amendment to the license condition. Attachment III provides markups of USAR Appendix 9.5E.

USAR Appendix 9.5 E provides a design comparison to 10 CFR 50 Appendix R.

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

ET 12-0022 Page 2 of 3 It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." Pursuant to 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Section (b),

no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

This amendment application was reviewed by the Plant Safety Review Committee. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," Section (b)(1),

a copy of this amendment application, with attachments, is being provided to the designated Kansas State official.

WCNOC requests approval of this license amendment request prior to November 1, 2013. It is anticipated that the license amendment, as approved, will be effective upon issuance and will be implemented within 90 days from the date of issuance.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4085, or Mr. Gautam Sen at (620) 364-4175.

Sincerely, 2f4/-Am/vA John P. Broschak JPB/rlt Attachments: I Evaluation of Proposed Change II Markup of Operating License III Markup of USAR Pages cc: B. J. Benney (NRC), w/a E. E. Collins (NRC), w/a T. A. Conley (KDHE), w/a N. F. O'Keefe (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 12-0022 Page 3 of 3 STATE OF KANSAS )

COUNTY OF COFFEY )

John P. Broschak, 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.

SUBSCRIBED and sworn to before me this 8 r day of Uckloer ,2012.

fJy GAYLE SHEPHEARD 1 Notary F&blic M& Notary Public- $tate of Kansas Apt.

pMyExpires ' /5 Expiration Date____________

Attachment I to ET 12-0022 Page 1 of 15 EVALUATION OF PROPOSED CHANGE

Subject:

License Amendment Request for Deviation from Fire Protection Program Requirements - Volume Control Tank Outlet Valves

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES

Attachment I to ET 12-0022 Page 2 of 15

1.

SUMMARY

DESCRIPTION The proposed amendment request is requesting Nuclear Regulatory Commission (NRC) approval, pursuant to License Condition 2.C(5), to make changes to the approved fire protection program as described in the Updated Safety Analysis Report (USAR). Specifically, a deviation from the separation requirements of 10 CFR 50, Appendix R, Section III.G.2, as documented in Appendix 9.5E of the WCGS Updated Safety Analysis Report (USAR), is requested for the volume control tank (VCT) outlet valves (BGLCV01 12B and BGLCV01 12C).

2. DETAILED DESCRIPTION License Condition 2.C(5)(a) currently states:

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment No.

191, and Amendment No. 193 subject to provisions b and c below.

License Condition 2.C(5)(a) is revised to state:

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment No.

191, Amendment No. 193, and Amendment No. XXX subject to provisions b and c below.

The proposed change reflects the approved fire protection program based on the issuance of the license amendment approving the proposed change. The amendment number will be reflected in the license condition upon the issuance of the amendment.

The Wolf Creek Generating Station (WCGS) response to Section IllI.G in USAR Table 9.5E-1 (Sheet 7), is revised by adding the following statement:

In fire area A-8, the volume control tank outlet valves (BGLCV01 12B and BGLCV01 12C) and circuits are not separated in accordance with Section III.G.2. However, the fire protection features provided in fire area A-8 as well as the low fixed combustible loading provides reasonable assurance that at least one valve will respond to a control room close signal following a fire in the area.

Enforcement Guidance Memorandum (EGM) 09-002, "Enforcement Discretion for Fire Induced Circuit Faults," Reference 1, granted enforcement discretion from certain fire protection requirements related to multiple spurious actuations. The EGM specified that enforcement discretion is limited to three years from the date of issuance of Regulatory Guide (RG) 1.189 (Reference 2), Revision 2, "Fire Protection for Nuclear Power Plants." Reference 3 identifies the date of issuance of RG 1.189, Revision 2, as November 2, 2009. In accordance with EGM 09-002, enforcement discretion is granted as follows:

Attachment I to ET 12-0022 Page 3 of 15

1. Six months following issuance of RG 1.189, Revision 2, for licensees to identify noncompliances related to multiple fire induced circuit faults, place the noncompliances in their corrective action program and implement compensatory measures for the noncompliances, and

2. Three years following the issuance of RG 1.189, Revision 2, for licehsees to complete the corrective actions associated with noncompliant multiple fire induced circuit faults.

On April 20, 2010, Wolf Creek Nuclear Operating Corporation (WCNOC) completed the six-month actions identified in EGM 09-002 by identifying noncompliances, placing the noncompliances in the corrective action program and implementing compensatory measures.

WCNOC documented the noncompliances in Condition Report 00025002. Compensatory measures were implemented in accordance with the approved fire protection program. In addition, consistent with Regulatory Issue Summary (RIS) 2005-07 (Reference 4),

"Compensatory Measures to Satisfy the Fire Protection Program Requirements," WCNOC implemented alternative compensatory measures by revising procedure OFN KC-016, "Fire Response," to provide operators additional instructions in the event of a fire. One of these noncompliances will be resolved by NRC review and approval of the proposed change to USAR Table 9.5E-1 for the volume control tank outlet valves.

3. TECHNICAL EVALUATION

System Description

The VCT provides surge capacity for part of the reactor coolant expansion volume not accommodated by the pressurizer. When the level in the tank reaches the high level setpoint, the remainder of the expansion volume is accommodated by diversion of the letdown stream, upstream of the VCT, to the boron recycle system. To prevent large hydrogen pressure swings in the VCT, and undesirable hydrogen concentrations in the Reactor Coolant System (RCS), it is desirable to maintain the level at the upper limit of the normal range. For optimal hydrogen pressure control, the level should be maintained between 50 and 60% whenever possible. The tank also provides a means for introducing hydrogen to the coolant to maintain the required equilibrium concentration of 25 to 50 cc hydrogen (at standard conditions for temperature and pressure) per kilogram of water and is used for degassing the reactor coolant. The VCT also serves as a head tank for the Emergency Core Cooling System (ECCS) centrifugal charging pumps (CCPs) and the normal charging pump.

WCGS Fire Protection Program License Basis The WCGS Renewed Facility Operating License, NPF-42, Section 2.C(5) conditions the operating license as follows regarding fire protection:

(5) Fire Protection (Section 9.5.1, SER, Section 9.5.1.8, SSER #5)

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, and as approved in the SER through Supplement 5, Amendment No. 191, and Amendment No. 193 subject to provisions b and c below.

Attachment I to ET 12-0022 Page 4 of 15 (b) The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(c) Deleted The proposed change has been determined to adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Therefore, prior Commission approval is required asSection III.G.2 of Appendix R is not directly satisfied.

The WCGS USAR, Appendix 9.5E, provides a comparison of the WCGS Fire Protection Program against the requirements of Section III of Appendix R to 10 CFR 50. Although WCGS obtained its operating license after January 1, 1979, the NRC stated, in NUREG-0881 (Reference 5), "Safety Evaluation Report related to the operation of Wolf Creek Generating Station, Unit No. 1," (hereinafter referred to as "SER") that the Staff would condition the WCGS operating license to require WCGS to meet the technical requirements of Appendix R to 10 CFR 50, or provide equivalent protection. However, the condition never appeared in the WCGS full power operating license when it was issued on June 4, 1985. Therefore, although Appendix R does not apply, WCGS's commitment to Appendix R is established in Appendix 9.5E as part of the approved Fire Protection Program documented in the USAR.

Appendix R,Section III.G.2 requires the following where redundant cables and equipment are located in the same fire area:

a) Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier; b) Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or c) Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.

The WCGS response to the requirements of Section III.G.2, as documented in the WCGS USAR, Table 9.5E-1 states, in part:

For a fire outside the control room, fire protection features are provided such that post-fire hot standby can be achieved and maintained from the control room, with limited reliance on operator manual actions outside the control room. Predominantly, redundant safe shutdown components are separated by 3-hour fire rated barriers or the equivalent protection identified by III.G.2. In some instances, operator manual actions outside the control room are utilized in lieu of III.G.2 protection. Operator manual actions have been evaluated for feasibility and reliability, considering NUREG-1852 guidance.

Attachment I to ET 12-0022 Page 5 of 15 Post-Fire Safe Shutdown Function The VCT outlet valves are credited in the Post-Fire Safe Shutdown Analysis (PFSSDA) for isolating the VCT from the charging header. If the VCT outlet valves are not isolated and letdown spuriously isolates, the VCT could drain and allow hydrogen into the ECCS CCP suction. This would damage the operating CCP and potentially prevent fulfilling the makeup and boration functions. Letdown is not credited for post-fire safe shutdown and it is assumed to be lost. However, as discussed below, a fire in the VCT valve compartment (room 1318) will not affect letdown.

Physical Description of Room/Area The VCT outlet valves are located in room 1318 and are separated by approximately 2 feet (See Figure 1). The physical arrangement of the VCT discharge piping makes it impractical to achieve any of the separation options of Appendix R,Section III.G.2.

Figure 1 - VCT Outlet Valves

Attachment I to ET 12-0022 Page 6 of 15 See Figure 2 for a simplified plan view of the Auxiliary Building 2000 elevation.

Fire area A-8 consists of almost the entire 2000 foot elevation of the Auxiliary Building. The area is separated from adjoining fire areas by 3-hour rated barriers.

Room 1318 is separated to the north and south by 3-hour fire rated barriers. The floor and ceiling of this room are also 3-hour fire rated barriers. The east and west walls are made of reinforced concrete construction but are not 3-hour fire rated because unprotected openings exist in these walls.

A normally locked, woven wire gate is installed at the entrance to room 1318. This is the only unprotected opening in the east wall of room 1318. The northern most VCT outlet valve (BGLCV01 12B) is located approximately 12 feet west of the door opening. Both the VCT valve compartment and the VCT room (room 1313) are administratively controlled as a transient combustible free zone with strict permitting requirements for unattended storage of transient combustibles. The locked gate, as well as the administrative controls, limits the possibility of unauthorized storage of combustibles in rooms 1313 and 1318.

0) rt Figure 2 - Auxiliary Building - 2000 elevation o rt-(1A H rr 0

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.-e, -eA-8A -33 0=lye E4 Aom_ _r -

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,.,A-30 ,-A-AUXIUARY BLDG EL.2000'

Attachment I to ET 12-0022 Page 8 of 15 Defense-in-Depth Evaluation The concept of defense-in-depth, described in 10 CFR 50, Appendix R, is applied to the WCGS Fire Protection Program, including fire area A-8, with the following three objectives:

1. Prevent fires from starting;

2. Detect rapidly, control, and extinguish promptly those fires that do occur; and,

3. Provide protection of structures, systems, and components (SSCs) important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent safe shutdown of the plant.

These three defense-in-depth objectives, as they relate to fire area A-8, are discussed in detail below.

1. Prevent fires from starting

a. One element of fire prevention is maintained through the design control process. The design change process invoked by procedure AP 05-002, "Dispositions and Change Packages," ensures that the fire protection group is involved with design changes that affect fire protection program items, including but not limited to, fire hazards analysis, PFSSD analysis, and combustible loading analysis. This review ensures that plant changes satisfy the fire protection program license basis.

b. With limited exception (example: cords and computer cable) WCGS utilizes IEEE-383, "Standard for Type Test of Class 1E Electric Cables, Field Splices, and Connections for Nuclear Power Generating Stations," rated thermoset cable within safety related areas in an effort to reduce the potential for fire ignition and propagation.

Attachment 5, "Characterizing Non-Simple Fire Ignition Sources," to Appendix F of NRC Inspection Manual 0609, "Fire Protection Significance Determination Process," states, in part, the following regarding the plausibility of self-ignited cable fires:

Self-ignited cable fires are considered plausible only for thermoplastic or non-qualified thermoset cables. Self-ignited cable fires will be assumed to be implausible for Thermoset cables rated as low flame spread per the IEEE-383 standard. If self-ignited cable fires are not plausible, they will not be considered in the Fire Protection SDP analysis (no self-ignited cable fire scenarios need to be developed).

This approach is consistent with Electric Power Research Institute (EPRI) technical report TR-100370, "Fire-Induced Vulnerability Evaluation (FIVE)," which identifies that IEEE-383 rated cable is not typically considered a fire source initiator due to a low ignition frequency, considering past nuclear power plant experience and fire tests.

Considering the above discussion, self-ignited cable fires involving IEEE-383 rated cable are not considered credible.

Due to the limited heat release rate associated with the failure of normal lighting fixtures, emergency lighting units, and public address equipment, these components are not considered a significant ignition source that would promote fire propagation. This approach is supported by the fact that Appendix F of NRC Inspection Manual 0609 does not identify normal lighting or communication equipment as ignition sources to be

Attachment I to ET 12-0022 Page 9 of 15 tabulated. Additionally, the inspection manual specifically excludes the tabulation of emergency lighting unit batteries as an ignition source.

c. Fire hazards within fire area A-8 consist of electrical cables and equipment. The most significant electrical fire hazard in the area is 480 VAC load center PG19, which is located approximately 55 feet south of the room 1318 door opening. The closest relevant ignition source within 20 feet of the room 1318 door opening is a 480 VAC lighting transformer (XQA22) that is mounted on the east wall of corridor 1320. The transformer is located approximately 9 feet off the floor and is approximately 16 feet from the room 1318 door opening. When applying the guidance from Appendix F of NRC Inspection Manual 0609, neither VCT outlet valve is within the zone of influence radius for this potential ignition source.

Cable trays are located in the hallway to the east of room 1318 and contain IEEE-383 rated cables. Some of the trays are provided with sheet metal covers.

Hydrogen is piped to the VCT to chemically remove dissolved oxygen from the RCS.

The pipe penetrates the floor of fire area A-8 approximately 15 feet south of the room 1318 door opening. The seismically supported pipe enters room 1318 on the south end and runs along the east and north walls of room 1318 where it penetrates the west wall of room 1318 and connects to the VCT. The hydrogen piping within fire area A-8 is schedule 40 stainless or carbon steel with welded fittings. There are no threaded or soldered fittings in the hydrogen piping within fire area A-8. Two isolation valves are present in the hydrogen piping in room 1318. One (BGV0483) is a %" ASME Section III packless (zero stem leakage) globe valve. The normally closed valve isolates a capped vent line. The remaining valve (BGV0084) is a 2" ASME Section III diaphragm valve.

The normally closed valve isolates the VCT from the waste gas decay tank. A review of work order history for BGV0483 and BGV0084 reveals that there have been no performance issues with either of these valves. Due to the robust design of the hydrogen piping and the favorable performance history of the valves in the hydrogen line within room 1318, a credible fire is not postulated to affect the hydrogen piping, and hydrogen is not considered a fuel source for a fire in this area.

Fixed combustible loading is documented in calculation XX-X-004, "Combustible Fire Loading For Each Room In The Various Fire Areas At WCNOC," Revision 4. Based on this calculation, which is consistent with the field configuration, room 1318 has negligible fixed combustibles. An emergency light is located on the west wall of room 1318, between the electrical conduits for the VCT outlet valves. As previously discussed, an emergency light unit is not considered to pose a significant fire hazard.

d. Daily fire prevention is controlled though the implementation of administrative procedures. Hot work activity is controlled by procedure AP 10-101, "Control of Transient Ignition Sources." This procedure requires the application of a qualified, dedicated fire watch when performing hot work activities within 35 feet of a safety related area. Historically, WCGS has not experienced an unreasonable amount of hot work fire events, and those that have occurred have been rapidly detected and extinguished at the incipient stage. Considering WCGS's historical performance regarding the ability to prevent hot work fire events of magnitude, it is reasonable to conclude that the likelihood of a hot work induced fire event is extremely low.

The transient combustible loading allowance for plant areas are included within calculation XX-X-004 to ensure the fire hazard categorization remains consistent with

Attachment I to ET 12-0022 Page 10 of 15 that considered in E-1F9905, "Fire Hazard Analysis." Transient combustible control is implemented by procedure AP 10-102, "Control of Combustible Materials," with transient combustible material allowances that are commensurate with PFSSD vulnerability.

Rooms 1313 and 1318 have been classified, and are physically identified in the field, as combustible control zones per Attachment C of AP 10-102. Administrative controls for combustible control zones do not allow any unattended combustible material quantities without a review by the fire protection group.

The administrative controls in place at WCGS provide reasonable assurance that introduction of transient combustible materials and other fire hazards in rooms 1313 and 1318 will be minimal.

2. Detect rapidly, control, and extinguish promptly those fires that do occur

a. Reliable, active fire detection and suppression systems, described in Wolf Creek System Description, M-10KC, "Fire Protection Systems (KC & FP)," and depicted on plant drawings, are provided, as required by E-1F9905, "Fire Hazard Analysis." Active fire protection features (fire pumps, firewater distribution, automatic detection, sprinkler, and Halon) were installed predominantly per the National Fire Protection Association (NFPA) code of record delineated in the USAR. The NRC accepted the original installation of these systems as described in the SER. Code deficiencies are evaluated for acceptability. Fire protection systems are periodically tested in accordance with the frequency requirements specified in procedure AP 10-100, "Fire Protection Program."

Fire area A-8 is provided with a partial automatic smoke detection system. Detectors are not provided in rooms with little or no combustible loading and no safe shutdown circuits or equipment. Room 1318 is provided with two automatic smoke detectors due to the presence of safe shutdown circuits in the room. These detectors were not part of the original design but were added in 2008 to enhance the defense-in-depth fire protection in the room. The original fire detection configuration was found to be acceptable by the Staff as documented in SER Section 9.5.1.4, "Fire Protection For Specific Areas."

An automatic pre-action sprinkler system protects areas containing concentrations of cables in trays. The protected area includes the hallway east of room 1318 as well as the west and north hallways. The pre-action sprinkler system, designated as system SKC-44, has been hydraulically calculated and shown to provide a minimum density of 0.3 gpm/ft 2 over 3,000 square feet. The fire protection water supply was shown to be capable of delivering a minimum flow of 1,194 gpm at 118.8 psi with a margin of 58.0 psi. The average density with this flow rate is 0.40 gpm/ft , which exceeds the required density of 0.30 gpm/ft by 25%.

b. Portable fire extinguishers and fire hose stations are provided throughout the plant for manual fire fighting efforts. They were installed predominantly per the NFPA code of record.

c. A qualified minimum five-member fire brigade is available to investigate and respond to fire events in a prompt and efficient manner. An initial and periodic continuing training program is applied to ensure fire brigade proficiency, which has historically been acceptable, as demonstrated by successful annual audits conducted by loss control representatives from the Station's insurer, Nuclear Electric Insurance Limited (NEIL).

Attachment I to ET 12-0022 Page 11 of 15

3. Provide protection of structures, systems, and components (SSCs) important to safety so that a fire that is not promptly extin-guished by fire suppression activities will not prevent safe shutdown of the plant.

a. Passive fire barrier features (walls, floors/ceilings, fire dampers, doors, penetration seals, fire wrap, and structural steel fireproofing) separating redundant PFSSD components were predominantly installed in accordance with industry standards and fire tested assemblies. Fire barrier configurations that are unique or are not directly bounded by fire testing are evaluated for acceptability in document M-663-00017A, "Fire Protection Evaluations for Unique Or Unbounded Fire Barrier Configurations." Passive fire barrier features are periodically tested/inspected (as applicable) in accordance with the frequency requirements specified in procedure AP 10-100, "Fire Protection Program."

b. Fire Wrap Protection - Fire Area A-8 The power and control cables associated with VCT outlet valve BGLCV01 12C are protected with a qualified 1-hour fire rated enclosure where the cables run in the east hallway, room 1320. The 1-hour fire barrier and automatic suppression and detection in room 1320 meet the separation requirements of 10 CFR 50, Appendix R, Section III.G.2.c. Therefore, reasonable assurance is provided that a fire in room 1320 will not affect the ability to close valve BGLCV01 12C from the control room.

An instrument cable associated with VCT level transmitter BGLT0185 is run in room 1320 and is protected with a qualified 1-hour fire barrier. The level transmitter is located in a separate fire area (A-34) and is unaffected by a fire in fire area A-8. The 1-hour fire barrier and automatic suppression and detection in room 1320 meet the separation requirements of 10 CFR 50, Appendix R, Section IIl.G.2.c. Therefore, reasonable assurance is provided that a fire in fire area A-8 will not affect the operation of BGLT01 85 nor prevent the ability to monitor VCT level from the control room using level indicator BGLI01 85.

c, Electrical Cable Routing - Fire Area A-8 The power and control cables for VCT outlet valves are run in rigid steel conduit in room 1318. The conduits are run in opposite directions to achieve the maximum possible separation. Valve BGLCV01 12B is located north of valve BGLCV01 12C. The conduit (1 U1J3H) for valve BGLCV01 12B runs slightly north then turns west where it penetrates a concrete wall into room 1313. The conduit then penetrates another concrete wall and enters the west corridor (room 1301) where the cable drops into cable tray 1J1E39 and runs north to the far northwest corner of fire area A-8 where it turns west and enters fire area C-18.

The conduit (4U3D5P) for valve BGLCV0112C runs south to the south wall of room 1318 then runs east along the south wall where it penetrates a concrete wall into the east corridor of fire area A-8 (room 1320) and turns up through the floor into fire area A-

16. In room 1320, the conduit is protected with a 1-hour fire resistive material.

Attachment I to ET 12-0022 Page 12 of 15

d. VCT Level Indication - Fire Area A-8 VCT level transmitter BGLT0185 is located in fire area A-34. The instrument cable associated with this level transmitter is run in fire area A-8 but is protected by a 1-hour fire barrier as discussed above in Section 3.b. Therefore, in the event of a fire in fire area A-8, VCT level indication is available and operators can diagnose a decreasing VCT level. A low-low (5%) level in the VCT sensed by BGLT0185 will start the refueling water sequence and automatically open the refueling water storage tank (RWST) to charging header valve BNLCV0112E. When valve BNLCV0112E is fully open, VCT outlet valve BGLCV01 12C is designed to automatically close. However, if BGLCV0112C is affected by the fire, BGLCV0112B can be closed from the control room. Valve BNLCV01 12E is unaffected by a fire in fire area A-8.

e. Availability of Normal Letdown - Fire Area A-8 Normal letdown provides makeup to the VCT from RCS Loop 3 crossover leg. A fire in room 1318 will not cause a loss of letdown to the VCT. Cables associated with the various valves in the letdown flowpath are not run in room 1318. The only scheduled cables in room 1318 are those associated with the VCT outlet valves and VCT level transmitter BGLT01 12.

A high water level in the VCT causes letdown to divert to the recycle holdup tank (RHUT). For this function, the water level is sensed by level transmitter BGLT0149, which is located outside of room 1318. Level transmitter BGLT01 12 does not provide the signal for this function. Therefore, a fire in room 1318 will not cause the letdown flow to divert to the RHUT.

VCT level transmitter BGLT01 12 monitors VCT level and initiates the refueling water sequence on low level in the VCT. This causes VCT outlet valve BGLCV01 12B to close and RWST to charging header valve BNLCV01 12D to open. This is the preferred lineup for PFSSD.

Based on the above discussion, there is reasonable assurance that a fire in room 1318 will not affect normal letdown and, therefore, VCT draindown will not occur.

4. REGULATORY EVALUATION 4.1 Applicable Regulatory RequirementslCriteria 10 CFR 50, Section 48, Fire protection, paragraph (a)(1) states, in part: "Each holder of an operating license issued under this part or a combined license issued under part 52 of this chapter must have a fire protection plan that satisfies Criterion 3 of appendix A to this part."

Paragraph (b) states, in part: "Appendix R to this part establishes fire protection features required to satisfy Criterion 3 of appendix A to this part with respect to certain generic issues for nuclear power plants licensed to operate before January 1, 1979."

10 CFR 50, Appendix R, Section III.G.2 states, in part: "Except as provided for in paragraph G.3 of this section, where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the

Attachment I to ET 12-0022 Page 13 of 15 following means of ensuring that one of the redundant trains is free of fire damage shall be provided:

a. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier;

b. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or

c. Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area."

10 CFR 50, Appendix A, Criterion 3-Fire protection. Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.

4.2 Significant Hazards Consideration The proposed amendment request is requesting Nuclear Regulatory Commission (NRC) approval, pursuant to License Condition 2.C(5), to make changes to the approved fire protection program as described in the Updated Safety Analysis Report (USAR). Specifically, a deviation from the separation requirements of 10 CFR 50, Appendix R, Section III.G.2, as documented in Appendix 9.5E of the WCGS Updated Safety Analysis Report (USAR), is requested for the volume control tank (VCT) outlet valves (BGLCV01 12B and BGLCV01 12C).

WCNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The design function of structures, systems and components (SSCs) are not impacted by the proposed change. An evaluation of not maintaining the 10 CFR 50, Appendix R, Section III.G.2, separation requirements for the volume, control tank outlet valves and associated circuits determined that the fire protection features provided in fire area A-8 as well as the low fixed combustible loading provides reasonable assurance that at least one valve will respond to a close signal from the control room following a credible fire in the area. The

Attachment I to ET 12-0022 Page 14 of 15 proposed change does not alter or prevent the ability of SSCs from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. Therefore, the probability of any accident previously evaluated is not increased. Equipment required to mitigate an accident remains capable of performing the assumed function.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change will not alter the requirements or function for systems required during accident conditions. An evaluation of not maintaining the 10 CFR 50, Appendix R, Section llI.G.2, separation requirements for the volume control tank outlet valves and associated circuits determined that the fire protection features provided in fire area A-8 as well as the low fixed combustible loading provides reasonable assurance that at least one valve will respond to a close signal from the control room following a credible fire in the area. The design function of structures, systems and components are not impacted by the proposed change.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on departure from nuclear boiling ratio (DNBR) limits, heat flux hot channel factor (FQ(Z)) limits, nuclear enthalpy rise hot channel factor (FAH) limits, peak centerline temperature (PCT) limits, peak local power density or any other margin of safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, WCNOC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Attachment I to ET 12-0022 Page 15 of 15

5. ENVIRONMENTAL CONSIDERATION WCNOC has evaluated the proposed changes and determined that the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6. REFERENCES

1. Enforcement Guidance Memorandum 09-002, "Enforcement Discretion for Fire Induced Circuit Faults," May 14, 2009.

2. Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants," Revision 2, October 2009.

3. Federal Register (74 FR 56673), "Notice of Issuance of Regulatory Guide," November 2, 2009.

4. Regulatory Issue Summary (RIS) 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements," April 19, 2005.

5. NUREG-0881, "Safety Evaluation Report related to the operation of Wolf Creek Generating Station, Unit No. 1," April 1982.

Attachment II to ET 12-0022 Page 1 of 2 Markup of Operating License

Attachment II to ET 12-0022 Page 2 of 2 5 (5) Fire Protection (Section 9.5.1, SER, Section 9.5.1.8, SSER #5)

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment No. 191, and Amendment No. 1 subject to provisions b and c below.

and Amend (b) The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(c) Deleted.

(6) Qualification of Personnel (Section 13.1.2, SSER #5, Section 18, SSER

1)