ML12318A145
| ML12318A145 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/05/2012 |
| From: | Lyon C Plant Licensing Branch IV |
| To: | Matthew Sunseri Wolf Creek |
| Lyon C | |
| References | |
| TAC ME5742 | |
| Download: ML12318A145 (34) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 December 5, 2012 Mr. Matthew W. Sunseri President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839
SUBJECT:
WOLF CREEK GENERATING STATION -ISSUANCE OF AMENDMENT RE:
CHANGES TO TECHNICAL SPECIFICATIONS 3.3,3.7, AND 3.8 (TAC NO.
ME5742)
Dear Mr. Sunseri:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 200 to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated February 23, 2011, as supplemented by letter dated October 25, 2012.
The amendment revises the WCGS TSs 3.3.7, "Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation," 3.3.8, "Emergency Exhaust System (EES) Actuation Instrumentation," 3.7.10, "Control Room Emergency Ventilation System (CREVS),"
3.7.11, "Control Room Air Conditioning System (CRACS)," 3.7.13, "Emergency Exhaust System (EES)," 3.8.2, "AC [Alternating Current] Sources - Shutdown," 3.8.5, "DC [Direct Current]
Sources - Shutdown," 3.8.8, "Inverters - Shutdown," and 3.8.10, "Distribution Systems Shutdown." Specifically, the proposed amendment: 1) deletes MODES 5 and 6 from the Limiting Condition for Operation (LCO) Applicability for the CREVS and its actuation instrumentation (TS 3.7.10 and TS 3.3.7, respectively); 2) deletes the Required Action from TS 3.7.10 and TS 3.7.11 that requires verifying that the OPERABLE CREVS/CRACS train is capable of being powered by an emergency power source; 3) revises TS 3.7.13 by incorporating a 7-day Completion Time for restoring an inoperable EES train to OPERABLE status during shutdown conditions; 4) adopts NRC-approved Technical Specification Task Force (TSTF) Change Traveler TSTF-36-A, Revision 4, "Addition of LCO 3.0.3 N/A [not applicable] to shutdown electrical power specifications," for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10; and 5) adds a more restrictive change to the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 such that these LCOs apply not only during MODES 5 and 6, but also during the movement of irradiated fuel assemblies regardless of the MODE in which the plant is operating.
M. Sunseri -2 A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482
Enclosures:
- 1. Amendment No. 200 to NPF-42
- 2. Safety Evaluation cc w/encls: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 200 License No. NPF-42
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment to the Wolf Creek Generating Station (the facility)
Renewed Facility Operating License No. NPF-42 filed by the Wolf Creek Nuclear Operating Corporation (the Corporation), dated February 23, 2011, and supplemented by letter dated October 25, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations setforth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
Enclosure 1
-2
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-42 is hereby amended to read as follows:
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 200, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3. The license amendment is effective as of its date of issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: December 5, 2012
4 (5) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) The Operating Corporation, pursuant to the Act and 10 CFR Parts 30,40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level The Operating Corporation is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100%
power) in accordance with the conditions specified herein.
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 200, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3) Antitrust Conditions Kansas Gas & Electric Company and Kansas City Power & Light Company shall comply with the antitrust conditions delineated in Appendix C to this license.
(4) Environmental Qualification (Section 3.11, SSER #4, Section 3.11, SSER #5)*
Deleted per Amendment No. 141.
- The parenthetical notation following the title of many license conditions denotes the section of the supporting Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
Renewed License No. NPF-42 Amendment No. 200
ATTACHMENT TO LICENSE AMENDMENT NO. 200 RENEWED FACILITY OPERATING LICENSE NO. NPF-42 DOCKET NO. 50-482 Replace the following pages of the Renewed Facility Operating License No. NPF-42 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Renewed Facility Operating License REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT 3.3-51 3.3-51 3.3-53 3.3-53 3.3-54 3.3-54 3.7-26 3.7-26 3.7-27 3.7-27 3.7-30 3.7-30 3.7-33 3.7-33 3.7-34 3.7-34 3.8-18 3.8-18 3.8-19 3.8-19 3.8-28 3.8-28 3.8-35 3.8-35 3.8-39 3.8-39
CREVS Actuation Instrumentation 3.3.7 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D .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 /> associated Completion Time for Condition A, B AND or C not met in MODE 1, 2, 3,or4. D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. Required Action and E.1 Suspend CORE Immediately associated Completion ALTERATIONS.
Time for Condition A, B or C not met during AND movement of irradiated fuel assemblies. E .2 Suspend movement of Immediately irradiated fuel assemblies.
SURVEILLANCE REQUIREMENTS
NOT E--------------------------------------------------------------
Refer to Table 3.3.7-1 to determine which SRs apply for each CREVS Actuation Function.
SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.7.2 Perform COT. 92 days (continued)
Wolf Creek - Unit 1 3.3-51 Amendment No. 123, 183,200
CREVS Actuation Instrumentation 3.3.7 Table 3.3.7-1 (page 1 of 1l CREVS Actuation Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE FUNCTION CONDITIONS CHANNELS REQUIREMENTS TRIP SETPOINT
- 1. Manual Initiation 1,2,3,4, 2 SR 3.3.7.4 NA and (al
- 3. Control Room Radiation- 1,2,3,4, 2 SR 3.3.7.1 (b)
Control Room Air Intakes and (al SR 3.3.7.2 SR 3.3.7.5
- 4. Containment Isolation - Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.a, for all initiation functions and Phase A requirements.
(al During movement of irradiated fuel assemblies.
(b) Trip Setpoint concentration value (/lCi/cm;) is to be established such that the actual submersion dose rate would not exceed 2 mRlhr in the control room.
Wolf Creek - Unit 1 3.3-53 Amendment No. 123, 132, 183,200
EES Actuation Instrumentation 3.3.8 3.3 INSTRUMENTATION 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation LCO 3.3.8 The EES actuation instrumentation for each Function in Table 3.3.8-1 shall be OPERABLE.
APPLICABILITY: According to Table 3.3.8-1.
ACTIONS
NOTES-----------------------------------------------------------
- 1. LCO 3.0.3 is not applicable.
- 2. Separate Condition entry is allowed for each Function.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Place one EES train in the 7 days with one channel or train Fuel Building Ventilation inoperable. Isolation Signal (FBVIS) mode.
(continued)
Wolf Creek - Unit 1 3.3-54 Amendment No. 123, 183,200
CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS)
LCO 3.7.10 Two CREVS trains shall be OPERABLE.
-.---------------------------------------------NOT E---------------------------------------------
The control room envelope (CRE) and control building envelope (CBE) boundaries may be opened intermittently under administrative controls.
APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREVS train A.1 Restore CREVS train to 7 days inoperable for reasons OPERABLE status.
other than Condition B.
B. One or more CREVS trains B.1 Initiate action to Immediately inoperable due to an implement mitigating inoperable CRE boundary actions.
or an inoperable CBE boundary in MODES 1, 2, AND 3,or4.
B.2 Verify mitigating actions to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant radiological exposures will not exceed limits and CRE occupants are protected from chemical and smoke hazards.
AND B.3 Restore CRE boundary 90 days and CBE boundary to OPERABLE status.
(continued)
Wolf Creek - Unit 1 3.7-26 Amendment No. 12a, 1a4, 171,177, 179,184,200
CREVS 3.7.10 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREVS train in CRVIS Time of Condition A not mode.
met during movement of irradiated fuel assemblies. OR D.2.1 Suspend CORE Immediately ALTERATIONS.
AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.
E. Two CREVS trains E.1 Suspend CORE Immediately inoperable during AL TERATIONS.
movement of irradiated fuel assemblies. AND OR E.2 Suspend movement of Immediately irradiated fuel assemblies.
One or more CREVS trains inoperable due to an inoperable CRE boundary or an inoperable CBE boundary during movement of irradiated fuel assemblies.
(continued)
Wolf Creek - Unit 1 3.7-27 Amendment No. 123, 131,134,171, 177,179,184,200
CRACS 3.7.11 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Place OPERABLE Immediately associated Completion CRACS train in operation.
Time of Condition A not met in MODE 5 or 6, or OR during movement of irradiated fuel assemblies. C.2.1 Suspend CORE Immediately AL TERATIONS.
AND C.2.2 Suspend movement of Immediately irradiated fuel assemblies.
D. Two CRACS trains 0.1 Suspend CORE Immediately inoperable in MODE 5 or 6, ALTERATIONS.
or during movement of irradiated fuel assemblies. AND 0.2 Suspend movement of Immediately irradiated fuel assemblies.
E. Two CRACS trains E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3,or4.
Wolf Creek - Unit 1 3.7-30 Amendment No. 123, 134, 171,177, 4-84,200
EES 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Emergency Exhaust System (EES)
LCO 3.7.13 Two EES trains shall be OPERABLE.
N 0 T E-----------------------------------------------
The auxiliary building or fuel building boundary may be opened intermittently under administrative controls.
APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies in the fuel building.
NOT E------------------------------------------------
The SIS mode of operation is required only in MODES 1, 2, 3, and 4. The FBVIS mode of operation is required only during movement of irradiated fuel assemblies in the fuel building.
ACTIONS
NOT E--------------------------------------------------------------
LCO 3.0.3 is not applicable to the FBVIS mode of operation.
CONDITION REQUIRED ACTION COMPLETION TIME A. One EES train inoperable. A.1 Restore EES train to 7 days OPERABLE status.
B. Two EES trains inoperable B.1 Restore auxiliary building 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to inoperable auxiliary boundary to OPERABLE building boundary in status.
MODE 1, 2, 3, or 4.
(continued)
Wolf Creek - Unit 1 3.7-33 Amendment No. 123, 132, 134, 171,177, 484,200
EES 3.7.13 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Two EES trains inoperable in MODE 1,2,3, or4 for reasons other than Condition B.
D. Required Action and D.1 Place OPERABLE EES Immediately associated Completion train in operation in FBVIS Time of Condition A not mode.
met during movement of irradiated fuel assemblies OR in the fuel building.
D.2 Suspend movement of Immediately irradiated fuel assemblies in the fuel building.
E. Two EES trains inoperable E,1 Restore fuel building 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to inoperable fuel boundary to OPERABLE building boundary during status.
movement of irradiated fuel assemblies in the fuel building.
I (continued)
Wolf Creek - Unit 1 3.7-34 Amendment No. 123, 132,134,171,177, 484,200
AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:
- a. One qualified circuit between the offsite transmission network and the onsite Class 1 E AC electrical power distribution subsystem required by LCO 3.8.10, "Distribution Systems - Shutdown"; and
- b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystems required by LCO 3.8.10.
- c. The shutdown portion of one load shedder and emergency load sequencer (LSELS) associated with the required DG and AC electrical power distribution train.
APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.
ACTIONS
I'JOTE----------------------------------------------------------
LCO 3.0.3 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite circuit -------------------N OT E--------------------
inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with the required train de-energized as a result of Condition A.
A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.
(continued)
Wolf Creek - Unit 1 3.8-18 Amendment No. 123, 163,200
AC Sources - Shutdown 3.8.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.1 Suspend CORE Immediately AL TERA TIONS.
AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.
AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.
AND A.2A Initiate action to restore Immediately required offsite power circuit to OPERABLE status.
B. One required DG B.1 Suspend CORE Immediately inoperable. AL TERATIONS.
AND B.2 Suspend movement of Immediately irradiated fuel assemblies.
AND B.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.
AND BA Initiate action to restore Immediately required DG to OPERABLE status.
(continued)
Wolf Creek - Unit 1 3.8-19 Amendment No. 123, 145, 163, 200
DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The Train A or Train B DC electrical power subsystem shall be OPERABLE to support one train of the DC electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems - Shutdown."
APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.
ACTIONS
NOT E----------------------------------------------------------
LCO 3.0.3 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A. Required DC electrical A.1 Declare affected required Immediately power subsystem feature(s) inoperable.
OR A.2.1 Suspend CORE Immediately ALTERATIONS.
A.2.2 Suspend movement of Immediately irradiated fuel assemblies.
A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.
A.2.4 Initiate action to restore Immediately required DC electrical power subsystem to OPERABLE status.
Wolf Creek - Unit 1 3.8-28 Amendment No. 123, 145, 163,200
Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters ~ Shutdown LCO 3.8.8 The Train A or Train B inverters shall be OPERABLE to support one train of the onsite Class 1E AC vital bus electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems - Shutdown."
APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.
ACTIONS
NOT E----------------------------------------------------------
LCO 3.0.3 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected required Immediately inverters inoperable. feature(s) inoperable.
OR A.2.1 Suspend CORE Immediately AL TERA TIONS.
AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.
AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.
AND A.2.4 Initiate action to restore Immediately required inverters to OPERABLE status.
Wolf Creek - Unit 1 3.8-35 Amendment No. 12d. 145, 163,200
Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of the Train A or Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support one train of equipment required to be OPERABLE.
APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.
ACTIONS
NOT E----------------------------------------------------------
LCO 3.0.3 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required AC, A.1 Declare associated Immediately DC, or AC vital bus supported required electrical power distribution feature(s) inoperable.
subsystems inoperable.
OR A.2.1 Suspend CORE Immediately AL TERATIONS.
A.2.2 Suspend movement of Immediately irradiated fuel assemblies.
A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.
AND (continued)
Wolf Creek - Unit 1 3.8-39 Amendment No. 123, 145, 163,200
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 200 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482
1.0 INTRODUCTION
By application dated February 23,2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110620288), as supplemented by letter dated October 25, 2012 (ADAMS Accession No. ML12310A195), Wolf Creek Nuclear Operating Corporation (the licensee) requested changes to the Technical Specifications (TSs) for Wolf Creek Generating Station (WCGS). The supplemental letter dated October 25, 2012, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on August 23, 2011 (76 FR 52704).
The proposed changes revise the WCGS TSs 3.3.7, "Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation," 3.3.8, "Emergency Exhaust System (EES)
Actuation Instrumentation," 3.7.10, "Control Room Emergency Ventilation System (CREVS),"
3.7.11, "Control Room Air Conditioning System (CRACS)," 3.7.13, "Emergency Exhaust System (EES)," 3.8.2, "AC [Alternating Current] Sources - Shutdown," 3.8.5, "DC [Direct Current]
Sources - Shutdown," 3.8.8, "Inverters - Shutdown," and 3.8.10, "Distribution Systems Shutdown." Specifically, the proposed changes: 1) delete MODES 5 and 6 from the Limiting Condition for Operation (LCO) Applicability for the CREVS and its actuation instrumentation (TS 3.7.10 and TS 3.3.7, respectively); 2) delete the Required Action from TS 3.7.10 and TS 3.7.11 that requires verifying that the OPERABLE CREVS/CRACS train is capable of being powered by an emergency power source; 3) revise TS 3.7.13 by incorporating a 7-day Completion Time for restoring an inoperable EES train to OPERABLE status during shutdown conditions; 4) adopt NRC-approved Technical Specification Task Force (TSTF) Change Traveler TSTF-36-A, Revision 4, "Addition of LCO 3.0.3 N/A [not applicable] to shutdown electrical power specifications," for TSs 3.3.8,3.7.13,3.8.2, 3.8.5, 3.8.8, and 3.8.10; and 5) add a more restrictive change to the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 such that these LCOs apply not only during MODES 5 and 6, but also during the movement of irradiated fuel assemblies regardless of the MODE in which the plant is operating.
Enclosure 2
-2
2.0 REGULATORY EVALUATION
The EES, CREVS, and CRACS are each designed to meet the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants" (GDC). Chapter 3, Section 3.1 of the Updated Final Safety Analysis Report (USAR) contains the GDC applicable to WCGS. Of these, GDC 61, "Fuel storage and handling and radioactivity control," specifically requires that nuclear power plant facilities be designed such that structures, systems, and components important to safety provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public. Hence, fuel storage and handling operations, radioactive waste, and other systems which may contain radioactivity, or have the potential to result in radiological consequences, shall be designed to assure adequate safety under normal and postulated accident (Le. fuel handling accident (FHA) or waste gas decay tank rupture accident) conditions. These actions and/or systems help to reduce the radioactive content in the fuel building exhaust following a postulated FHA or in the radwaste building following a postulated waste gas decay tank rupture accident so that offsite and control room (CR) doses remain within the applicable regulatory limits as specified below.
In addition to the NRC staff's evaluation of the requested changes of the impact of the proposed changes to the WCGS design basis analysis, the staff's review also ensures continued compliance with the requirements of GDC 19, "Control room," GDC 13, "Instrumentation and control," GDC 60, "Control of releases of radioactive materials to the environment," and GDC 64, "Monitoring of radioactivity releases," and 10 CFR 50.36, "Technical specifications," as supplemented by Section 6.4, "Control Room Habitability System," Revision 3, of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:
The purpose of the EES is to ensure that radioactive materials in the fuel building atmosphere following an FHA or waste gas decay tank rupture accident are filtered and adsorbed prior to being exhausted to the environment. The EES filters exhaust from the fuel building following receipt of a fuel building ventilation isolation signal (FBVIS), subsequent to receipt of a high radiation signal via the area radiation monitors. The EES has two independent and redundant trains. Each EES train consists of a heater, a pre-filter, a high efficiency particulate air (HEPA) filter bank, an activated charcoal absorber section for removal of gaseous activity (principally iodines), and a fan.
To ensure the CR is kept habitable for personnel during accident recovery and post-accident operations, the CREVS provides a protected environment from which operators can safely control the unit. The CREVS is designed in accordance with GDC 19 to maintain the CR environment for 30 days occupancy after a design-basis accident (DBA) without CR personnel exceeding a dose of 5 roentgen equivalent man (rem) whole body, or its equivalent to any part of the body. Upon actuation of the CREVS by receipt of a Control Room Ventilation Isolation Signal (CRVIS), the system acts to terminate the supply of unfiltered outside air to the CR, closes the unfiltered exhaust dampers to the CR, initiates filtration and aligns the system for recirculation, and pressurizes the CR in order to minimize the radiation exposure of CR personnel. During shutdown conditions (reactor MODES 5 and 6), only the FHA in the fuel building is of concern and is the event responsible for requiring the CREVS to be OPERABLE during movement of irradiated fuel assemblies. The CREVS consists of two independent and
- 3 redundant trains that pressurize, recirculate, and filter the CR air. Each CREVS train consists of a filtration system train and a pressurization system train. Each filtration system train consists of a fan, a pre-filter, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Each pressurization system train consists of a fan, a moisture separator, an electric heater, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines.
To ensure that air quality is maintained for personnel and essential equipment located inside the CR, the CRACS provides air temperature control. The CRACS is an emergency system which is designed in accordance with GDC 19 to provide and/or maintain CR temperature control for 30 days of continuous occupancy. The CRACS is capable of removing sensible and latent heat loads from the CR, which include consideration of equipment heat loads and personnel occupancy requirements, to ensure equipment operability. The CRACS consists of two independent and redundant trains that provide cooling of recirculated CR air. Each train consists of a high-efficiency pre-filter, self-contained refrigeration system, centrifugal fans, instrumentation, and controls to provide for CR temperature control.
This evaluation has been conducted to ensure that the radiological consequences of DBAs following the proposed changes would continue to meet the dose acceptance criteria given in 10 CFR 100.11, "Determination of exclusion area, low population zone, and population center distance." The dose acceptance criteria in 10 CFR Part 50, Appendix A, GDC 19, as supplemented by SRP Section 6.4, "Control Room Habitability System," was used by the staff for CR dose. The NRC staff used the regulatory guidance provided in NRC Regulatory Guide (RG) 1.24, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Pressurized Water Reactor Radioactive Gas Storage Tank Failure," March 1972 (ADAMS Accession No. ML083300020), RG 1.25, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors," March 1972 (ADAMS Accession No. ML083300022), and RG 1.195, "Methods and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Light-Water Nuclear Power Reactors," May 2003 (ADAMS Accession No. ML031490640). The NRC staff also referred to WCGS USAR, Chapter 15, Accident Analyses," in performing this review.
II The applicable acceptance criteria are 5 rem whole body, 30 rem thyroid, and 30 rem beta skin in the CR, 300 rem thyroid and 25 rem whole body at the exclusion area boundary (EAB), and 300 rem thyroid and 25 rem whole body at the outer boundary of the low population zone (LPZ).
SRP Section 15.7.4, "Radiological Consequences of Fuel Handling Accidents," provides FHA specific acceptance criteria of 25 percent or less of the 10 CFR Part 100 limits (i.e., 75 rem thyroid and 6.25 rem whole body) at both the EAB and LPZ. Additionally, the WCGS licensing basis provides more specific acceptance criteria of 10 percent or less of the 10 CFR Part 100 limits (i.e., 30 rem thyroid and 2.5 rem whole body at both the EAB and LPZ, respectively) for a postulated waste gas decay tank rupture accident at WCGS. The considerations provided in Section 7 of Regulatory Issue Summary (RIS) 2001-19, "Deficiencies in the Documentation of Design Basis Radiological Analyses Submitted in Conjunction with License Amendment Requests," dated October 18, 2001 (ADAMS Accession No. ML011860407), was also used by the licensee in performing the CR habitability analysis for the postulated waste gas decay tank
-4 rupture accident. The NRC staff's evaluation is based upon the licensee's previously approved postulated DBA analyses of record (AOR), and the descriptions and results presented in the licensee's license amendment request (LAR) dated February 23, 2011, as supplemented October 25, 2012.
The WCGS TSs are based on NUREG-1431, "Standard Technical Specifications -
Westinghouse Plants" (STS), which was found acceptable by the NRC staff for WCGS by Amendment No. 123 dated March 31,1999 (ADAMS Accession No. ML022050061).
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes 3.1.1 TS 3.3.7, "Control Room Emergency Ventilation System (CREVS)
Actuation Instrumentation" Current LCO 3.3.7 Condition Estates:
Required Action and associated Completion Time for Condition A, B or C not met in MODE 5 or 6, or during movement of irradiated fuel assemblies.
Revised LCO 3.3.7 Condition E would state:
Required Action and associated Completion Time for Condition A, B or C not met or during movement of irradiated fuel assemblies.
Current TS Table 3.3.7-1, CREVS Actuation Instrumentation," Functions 1, 2, and 3, Column "Applicability Modes or Other Specified Conditions," states:
1,2,3,4,5,6, and (a)
Revised TS Table 3.3.7-1, CREVS Actuation Instrumentation," Functions 1, 2, and 3, Column "Applicability Modes or Other Specified Conditions," would state:
1,2,3,4, and (a) 3.1.2 TS 3.3.8, "Emergency Exhaust System (EES) Actuation Instrumentation" Current LCO 3.3.8 ACTION NOTE states:
Separate Condition Entry is allowed for each Function The word "NOTE" would be made plural and revised LCO 3.3.8 ACTION NOTES would state:
- 1. LCO 3.0.3 is not applicable.
- 2. Separate Condition Entry is allowed for each Function.
- 5 3.1.3 TS 3.7.10, "Control Room Emergency Ventilation System (CREVSr Current LCO 3.7.10 APPLICABILITY states:
MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.
Revised LCO 3.7.10 APPLICABILITY would state:
MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies.
Current LCO 3.7.10 Condition D states:
Required Action and associated Completion Time of Condition A not met in MODE 5 or 6, or during movement of irradiated fuel assemblies.
Revised LCO 3.7.10 Condition D would state:
Required Action and associated Completion Time of Condition A not met or during movement of irradiated fuel assemblies.
In addition, current LCO 3.7.10 Required Action D.1.1 would be renumbered as Required Action D.1, the "AND" logical connector would be deleted, and the following Required Action D.1.2 and its associated Completion Time would be deleted:
D.1.2 Verify OPERABLE CREVS train is capable of Immediately being powered by an emergency power source.
Current LCO 3.7.10 Condition Estates:
Two CREVS trains inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies.
One or more CREVS trains inoperable due to an inoperable CRE boundary or an inoperable CBE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies.
Revised LCO 3.7.10 Condition E would state:
Two CREVS trains inoperable during movement of irradiated fuel assemblies.
One or more CREVS trains inoperable due to an inoperable CRE boundary or an inoperable CBE boundary during movement of irradiated fuel assemblies.
-6 3.1.4 TS 3.7.11, "Control Room Air Conditioning System (CRACS)"
CUrrent LCO 3.7.11 Required Action C.1.1 would be renumbered as C.1, the "AND" logical connector would be deleted, and the following Required Action C.1.2 and its associated completion time would be deleted:
C.1.2 Verify OPERABLE CRACS train is capable of Immediately being powered by an emergency power source.
3.1.5 TS 3.7.13, "Emergency Exhaust System (EES)"
A new ACTION NOTE would be added to LCO 3.7.13 which would state:
LCO 3.0.3 is not applicable to the FBVIS mode of operation.
Current LCO 3.7.13 Condition A states:
One EES train inoperable in MODE 1, 2, 3, or 4.
Revised LCO 3.7.13 Condition A would state:
One EES train inoperable.
Current LCO 3.7.13 Condition 0 states:
One EES train inoperable during movement of irradiated fuel assemblies in the fuel building.
Revised LCO 3.7.13 Condition 0 would state:
Required Action an associated Completion Time of Condition A not met during movement of irradiated fuel assemblies in the fuel building.
3.1.6 TSs 3.8.2, nAC Sources - Shutdown," 3.8.5, "DC Sources - Shutdown,' 3.8.8, "Inverters - Shutdown," and 3.8.10, "Distribution Systems - Shutdown" Currently, the APPLICABILITY for LCOs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 state:
MODES 5 and 6.
The revised APPLICABILITY for LCOs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 would state:
MODES 5 and 6, During movement of irradiated fuel assemblies.
-7 In addition, a new ACTION NOTE would be added to LCOs 3.8.2, 3.8.5, 3.8.8, and 3.8.10, which would state:
LCO 3.0.3 is not applicable.
3.2 NRC Staff Evaluation This safety evaluation (SE) provides an evaluation of the impact of the proposed changes on analyzed DBA dose consequences as a result of postulated FHA or waste gas decay tank rupture accident at WCGS. For the proposed TS changes submitted by the licensee, the FHA and the waste gas tank rupture are the only design basis events that are postulated to occur during shutdown conditions, for which these mitigating system functions are required or assumed.
A postulated FHA can be characterized by the dropping of both a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies. The FHA is postulated to occur during movement of irradiated fuel assemblies inside the containment or within the fuel building, whereas a fuel assembly could be dropped along the fuel transfer canal, in the fuel storage pool, in the cask loading pool, or in the fuel building its self. Waste gas storage tanks are used at WCGS to permit decay of radioactive gases as a means of reducing or preventing the release of radioactive materials to the environment. A postulated waste gas decay tank rupture accident is characterized by the release of the contents of one of these tanks into the radwaste building, resulting from a rupture of the tank, or of an inlet or discharge pipe, or because of operator error or valve malfunction.
3.2.1 Deletion of MODE 5 and 6 from WCGS TS 3.3.7 and WCGS TS 3.7.10 Control Room Radiological Consequences of a Waste Gas Decay Tank Rupture The applicability of the CREVS in MODES 5 and 6, and during movement of irradiated fuel assemblies, is to ensure CR habitability in the event of a postulated waste gas decay tank rupture accident or FHA. WCGS TS 3.7.10 and TS 3.3.7 collectively govern the applicability, operability, and functionality of the CREVS. In regard to the proposed change, the licensee proposes to revise WCGS TS 3.3.7 Condition E by deleting "in MODE 5 or 6, or" to read as follows:
Required Action and associated Completion Time for Conditions A, B, or C not met during movements of irradiated fuel assemblies.
In addition, WCGS TS Table 3.3.7-1, "CREVS Actuation Instrumentation," is proposed to be revised to delete "5, 6," under the APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS column for Functions 1, 2, and 3 (Manual Initiation, Automatic Actuation Logic and Actuation Relays, and Control Room Radiation - Control Room Air Intakes, respectively).
In regard to the proposed change to WCGS TS 3.7.10, the licensee proposes to delete MODES 5 and 6 from the LCO Applicability. Therefore, the LCO Applicability for WCGS TS 3.7.10 will be revised to be applicable only for MODES 1-4, and during movement of
- 8 irradiated fuel assemblies. WCGS TS 3.7.10 Condition D will be revised to delete the reference to MODES 5 and 6, and will read as follows, Required Action and associated Completion Time for Condition A not met during movement of irradiated fuel assemblies.
In addition to the above change, REQUIRED ACTION D.1.2 will be deleted from WCGS TS 3.7.10 Condition D in its entirety, the "AND" logical connector will be deleted, and the numbering for REQUIRED ACTION D.1.1 will be change to specifically read "D.1." Similarly, WCGS TS 3.7.10, Condition E, will be revised to delete the reference to MODES 5 and 6, and will read as follows:
Two CREVS trains inoperable during movement of irradiated fuel assemblies.
OR One or more CREVS trains inoperable due to an inoperable CRE boundary or an inoperable CBE boundary during movement of irradiated fuel assemblies.
The licensee's current AOR for the radiological consequences of a waste gas decay tank rupture accident calculated only the doses at the EAB and LPZ. The CR dose was not included because it was determined by the licensee that the design basis loss-of-coolant accident (LOCA) was the most limiting DBA with respect to CR habitability. The licensee reanalyzed the postulated waste gas decay tank rupture accident for WCGS, to include the resulting radiological consequences for the EAB, LPZ. and CR. with no credit being taken for the mitigation capability of the CREVS (Calculation No. AN-10-004, "Control Room Habitability of a Waste Gas Decay Tank Failure," March 2010). The licensee also stated that:
The results of the calculation have confirmed that the calculated radiological consequence values for a postulated waste gas tank rupture, with no credit being taken for the mitigation capability of the CREVS, are less than the regulatory limits for control room occupants, therefore, the CREVS and its actuation instrumentation are not required to be OPERABLE in MODES 5 and 6 to protect the control occupants. As such, deletion of MODES 5 and 6 from the Applicability for TS 3.7.10 and TS 3.3.7 is acceptable.
The licensee's radiological analysis is documented in Attachment I, Section 4.1, "Deletion of MODE 5 and 6 from WCGS TS 3.3.7 and WCGS TS 3.7.10 - Control Room Radiological Consequences of a Waste Gas Decay Tank Rupture," of its submittal. The licensee analyzed the waste gas decay tank rupture accident using the RADTRAD computer code based on the assumptions and parameters described in Attachment I, Section 4.1 and Table 1 of the LAR The licensee did not recalculate the FHA analysiS for this proposed change. By letter dated October 25, 2012, the licensee stated that the WCGS current licensing basis does not assume an FHA to occur concurrent with a loss of offsite power and a single failure. Therefore, the NRC staff determined that the FHA radiological dose analysis will remain bounding, because the proposed change does not impact WCGS current AOR
- 9 Additionally, the licensee noted that the STS and STS Bases for Westinghouse plants, as documented in NUREG-1431, Revision 3, dated March 2004, have brackets around the MODE 5 and MODE 6 Applicability in TS 3.3.7 and TS 3.7.10. The licensee stated that these brackets indicate that individual licensees would adopt MODES 5 and 6 if the waste gas decay tank rupture accident requires CR staff protection. The licensee stated that if the event requires no mitigation or CR habitability protection, then MODES 5 and 6 are not required in the LCO Applicability for TS 3.3.7 and TS 3.7.10. The licensee concluded that since the calculated values for the postulated waste gas decay tank rupture accident analysis are less than the regulatory limits for CR habitability, the CREVS and its actuation instrumentation is not needed to protect the CR occupants; therefore, the CREVS is not required to be operable in MODES 5 and 6 for the waste gas decay tank rupture accident. Based on the above stated analyses, the licensee proposes to delete MODES 5 and 6 from the modes of applicability for WCGS TS 3.7.10 and WCGS TS 3.3.7.
The NRC staff reviewed the licensee's evaluation, relying upon the information provided by the licensee, staff experience in performing similar reviews, and confirmatory calculations. The NRC staff confirmed the licensee's calculations and determined that the licensee's revised postulated waste gas decay tank rupture radiological consequences do not exceed a small fraction (10 percent) of the guideline values of 10 CFR Part 100 (Le., 2.5 rem and 30 rem, respectively, for the whole body and thyroid doses at both the EAB and LPZ). The NRC staff also determined that the licensee's radiological consequences for the CR are conservatively below the applicable regulatory acceptance criteria of GDC 19, as supplemented by SRP Section 6.4, for each of the indicated thyroid, whole body, and beta skin doses. Therefore, the CR will remain habitable following an accidental release of radioactivity from a postulated waste gas decay tank rupture accident, without credit for the CREVS and its actuation instrumentation. The licensee's calculated resulting doses can be found in Table 1 below.
Based on the above-stated analyses, the NRC staff concludes that the proposed changes to TS 3.3.7 and TS 3.7.10 are acceptable from a radiological consequence perspective of the postulated design basis accidents.
TABLE 1 Comparison of the Radiology Dose Consequence Results (in rem) of Revised Postulated Waste Gas Decay Tank Rupture Accident at Wolf Creek Generating Station Proposed Baseline Case Acceptance Criteria Amendment Exclusion Area Boundary (EAB)
Thyroid 3.648E-03 30.0 3.660E-03 Whole Body 1.302E-01 2.5 1.306E-01 Low Population Zone (LPZ)
Thyroid 4.867E-04 30.0 4.880E-04 Whole Body 1.736E-02 2.5 1.742E-02 Control Room (CR)
Thyroid N/A 30.0 1.449E-02 Whole Body N/A 5.0 2.158E-02 Beta Skin N/A 30.0 6.230E-01
- 10 3.2.2 Deletion of Required Action from WCGS TS 3.7.10 and WCGS TS 3.7.11 Emergency Power Source WCGS TS 3.7.10 and TS 3.7.11 govern the applicability, operability, and functionality of the CREVS and CRACS, respectively, to effectively mitigate a postulated waste gas decay tank rupture accident or FHA to ensure CR habitability at WCGS. As described in Attachment I of the LAR, Section 4.2, the licensee proposed to delete Required Action D.1.2 from WCGS TS 3.7.10 and Required Action C.1.2 from WCGS TS 3.7.11. Each of these are the "Required Action" that must be entered when one CREVS/CRACS train is inoperable for a period longer than 7 days, as specified in Condition A of each applicable TS, and which requires verifying that the OPERABLE train is capable of being powered by an emergency power source. This action assures OPERABILITY of the CREVS/CRACS train in the unlikely event of a FHA or waste gas decay tank rupture accident while shutdown concurrent with a LOOP.
The TS operability and applicability requirements of both the CREVS and the CRACS are very similar. Two independent and redundant CREVS and CRACS trains are required to be OPERABLE per TS 3.7.10 and TS 3.7.11, respectively, to ensure that at least one is available assuming a single failure disables the other train. Loss of both CREVS trains could result in exceeding a dose of 5 rem to the CR operator in the event of a large radioactive release. Loss of both CRACS trains could cause the equipment operating the CR temperature to exceed limits in the event of an accident.
The licensee stated that the FHA and waste gas tank rupture are postulated to occur during shutdown conditions, for which mitigating system functions are required or assumed. The FHA, in particular, may be postulated to occur during the movement of irradiated fuel assemblies in the fuel building during shutdown conditions. For events that are postulated to occur during shutdown conditions, the licensee stated that it is appropriate that the TSs continue to require both trains of the credited mitigating system(s) to be OPERABLE in order to accommodate a single failure (Le., a failure of either train in the event of a demand.) However, in keeping with the provisions described in the applicable TS Bases for shutdown conditions, the licensee stated that it is not necessary to assume that such an event occur concurrent with a loss of offsite power and a single failure. By letter dated October 25, 2012, the licensee stated that the WCGS current AOR does not assume a loss of offsite power concurrent with an FHA. In regards to the waste gas tank rupture analysis, the removal of MODES 5 and 6 from TS 3.7.10 and TS 3.7.11 is acceptable, based upon the calculation discussed in Section 3.2.1 of this SE.
Currently, TS 3.7.10 and TS 3.7.11 Required Actions D.1.2 and C.1.2, respectively, require verification that the operable CREVS and CRACS are capable of being powered by an emergency power source in order to assure operability of these trains in the unlikely event of an FHA or decay tank rupture while shut down concurrent with a loss of offsite power.
The licensee referenced Calculation No. AN-10-004, that confirmed that the calculated radiological consequence values for a postulated waste gas tank rupture, with no credit taken for the mitigation capability of the CREVS, are less than the regulatory limits for the control room occupants. Therefore, given that the unit is in MODE 5 or 6 and the low probability of an FHA, and the redundant trains of CREVS/CRACS is already in operation, there no concerns of a failure preventing automatic actuation of the redundant train, and any active failure would, or should be readily detected. It is the NRC staffs understanding that in the new Action D and the
- 11 new Action C, the operable CREVS and the operable CRACS train, respectively, is powered by normal electrical power and is capable of performing its intended safety function. This is acceptable to the staff, because these systems are operable in accordance with the staff accepted definition of operability as defined in the STS, and thereby reasonable assurance of public health and safety is provided. In accordance with the STS:
A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
The NRC staff reviewed Attachment I of the submittal, the corresponding TSs, and the WCGS USAR. The NRC staff determined that the radiological mitigating safety functions of both the CREVS and the CRACS will still be preserved from a radiological consequence perspective, and that CR habitability will still be maintained. The EAB and the LPZ dose results are unaffected because the CREV system only provides filtration to the control room.
Based on the above, the NRC staff concludes that the proposed changes to WCGS TS 3.7.10 and WCGS TS 3.7.11 are acceptable.
3.2.3 Revision of TS 3.7.13 to Incorporate 7-day Completion Time for Restoring an Inoperable EES Train to OPERABLE Status During Shutdown Conditions TS 3.7.13 governs the applicability, operability, and functionality of the EES to effectively mitigate a postulated waste gas decay tank rupture accident or FHA in the fuel building. As described in Attachment I, Section 4.3, the licensee proposes to incorporate a 7-day Completin Time for restoring an inoperable EES train to OPERABLE status for the MODE or condition of "during the movement of irradiated fuel assemblies in the fuel building." A 7-day Completion Time is already permitted for restoring an inoperable EES train during MODES 1, 2, 3, and 4 per Condition A (Le., Required Action A.1) of current TS 3.7.13. The licensee proposes to modify TS 3.7.13 Condition A so that the required action to restore an inoperable EES train is applicable during MODES 1, 2, 3, and 4, or during the movement of irradiated fuel assemblies in the fuel building.
The licensee's proposed 7-day Completion Time is also consistent with the provisions of the STS, for a system similar to the EES. In particular, STS 3.7.13, "Fuel Building Air Cleanup System (FBACS)," provides the requirements for a FBACS which ensures that radioactive materials in the fuel building atmosphere following an FHA or a LOCA are filtered and adsorbed prior to exhausting to the environment. In their submittal, the licensee identified a system comparison between the STS FBACS and the WCGS EES. In the event that one of two redundant trains of the FBACS is declared inoperable, Condition A of STS 3.7.13 applies in the same manner that Condition A does for an inoperable EES train under WCGS TS 3.7.13.
- 12 The licensee determined that STS 3.7.13 should be directly applicable to the EES and thus equivalent to WCGS's TS 3.7.13. Consistent with the provisions of STS 3.7.13, the licensee proposes to revise WCGS TS 3.7.13 Condition A to delete the reference to "MODES 1, 2, 3, or 4," and the revised condition statement will read, "One EES train inoperable." In addition, WCGS TS 3.7.13, Condition D will also be revised to read as follows:
Required Action and associated Completion Time of Condition A not met during movement of irradiated fuel assemblies in the fuel building.
The licensee stated that this change will add an exclusion from LCO 3.0.3 that recognizes that irradiated fuel movement in the fuel building is independent of reactor operation in MODES 1- 4; therefore, entering LCO 3.0.3 would require the unit to be shut down unnecessarily. The NRC staff agrees and concludes that the requested change is acceptable, because during the time that one EES train is inoperable, the remaining operable train is adequate to perform the EES function and the 7-day Completion Time is reasonable, due to the low probability of a DBA occurring during this time period.
The NRC staff also concludes that the proposed changes to WCGS TS 3.7.13 are acceptable from a radiological consequence perspective of postulated design basis accidents. since during the times that one EES train is inoperable, the remaining operable train is adequate to perform the EES function. Therefore, the NRC staff also determined that the proposed change has no effect on the parameters, assumptions, and/or methodology used in the radiological consequence analyses for WCGS, and the proposed changes to WCGS TS 3.7.13 are acceptable.
3.2.4 Adoption of TSTF-36-A, Change to Add LCO 3.0.3 Exceptions to TS 3.3.8, TS 3.7.13, TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10 TS 3.3.8 and TS 3.7.13 govern the applicability, operability, and functionality of the EES as stated in Sections 3.0 and 3.3 above. TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10 govern the applicability, operability, and functionality of the alternating current (AC) sources, direct current (DC) sources, inverters, and distribution systems, respectively. which also provide the requirements of the specific sub-systems associated with the WCGS electrical power system.
The WCGS electrical power system ensures that adequate power is supplied to support one train of each equipment, and/or system, required to be OPERABLE to effectively mitigate a postulated waste gas decay tank rupture accident or FHA.
The licensee requested to adopt traveler TSTF-36-A, Revision 4, "Addition of LCO 3.0.3 N/A to shutdown electrical power specifications." The use of this traveler will add an exclusion from WCGS LCO 3.0.3 to the applicable WCGS TS LCO Actions for which the movement of irradiated fuel is independent of reactor operation in MODES 1-4. The proposed change will result in removing the requirement to enter Cold Shutdown (MODE 5), per WCGS LCO 3.0.3, when an LCO that is Applicable during the movement of irradiated fuel is not met, and the compensatory Required Actions are not able to be carried out within the associated Completion Times. The licensee indicates a Cold Shutdown per LCO 3.0.3 does not provide an adequate compensatory action since movement of irradiated fuel assemblies in MODES 1, 2, 3, or 4 is independent of reactor operations.
- 13 In Attachment I, Section 4.4, of the LAR, the licensee stated that there should be no requirement for WCGS to experience the perturbations and shutdown transition risk associated with a forced reactor shutdown, per LCO 3.0.3, under the current requirements of TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. These TSs all contain a default Required Action to immediately suspend movement of irradiated fuel assemblies in the event other Required Actions or Completion Times are not met or for noncompliance with the LCO. Instead of potentially subjecting WCGS to potential perturbations and increased risk, the licensee asserts that the required response should be to continue taking steps to suspend fuel movement activities, and not enter LCO 3.0.3. The licensee concludes that an appropriate course of action for when an LCO applicable during the movement of irradiated fuel is not met is to continue efforts to carry out the Required Actions while still in the mode of applicability. This is ensured by WCGS TS 1.3, "Completion Times," whereas entering LCO 3.0.3 per the above stated TSs can potentially be contrary to the safe operation of WCGS. The licensee proposes to add a new ACTIONS NOTE 1 and renumber the existing note as NOTE 2. Therefore the new and/or revised "NOTES" will read as follows:
- 1. LCO 3.0.3 is not applicable to the FBVIS mode of operation.
- 2. Separate Condition entry is allowed for each Function.
The mechanical functions covered by TS 3.7.13 are split between the safety injection signal mode of operation in MODES 1-4, where the concern is auxiliary building ventilation isolation after a LOCA, and the fuel building ventilation isolation signal (FBVIS) mode of operation during movement of irradiated fuel assemblies in the fuel building, where the concern is fuel building ventilation isolation after a FHA TSTF-36-A was approved by the NRC to apply to STS 3.7.13, which also contains similar applicability.
The NRC staff concludes that the proposed changes to TSs 3.3.8, TS 3.7.13, TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10 are acceptable from a radiological consequence perspective of the postulated DBAs. Therefore, NRC staff has determined that the current calculated dose values remain bounding for the proposed TS changes.
3.2.5 Revision of the LCO Applicability for TSs 3.8.2,3.8.5,3.8.8, and 3.8.10 The licensee proposes expanding the applicability statements of TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10 to make the LCO requirements apply during movement of irradiated fuel assemblies. The STS and STS Bases for Westinghouse plants, NUREG-1431, include the following specified condition in the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10:
During movement of [recently] irradiated fuel assemblies.
The licensee stated that it is not adopting the bracketed "[recently]" portion of that specified condition at this time; it was the subject of a separate traveler (TSTF-51-A). However, the rest of the above-specified condition would be adopted. The licensee's LAR stated:
During full core offloads, no MODES apply per the TS 1.1 Definitions since there is no fuel in the reactor vessel. However, electrical power requirements should still be observed for the removal of decay heat from the spent fuel pool and to mitigate the potential consequences of a FHA in the fuel building.
- 14 The NRC staff determined that the proposed change is more restrictive than current TS requirements because the licensee's current TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10 are not applicable during movement of irradiated fuel. The proposed change would require all TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10 requirements to be met during movement of irradiated fuel. The NRC staff concludes that the proposed changes to WCGS TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 are acceptable from a radiological consequence perspective of the postulated DBAs.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Kansas State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on August 23,2011 (76 FR 52704). Accordingly, the amendment meets the eljgibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.
Principal Contributors: D. Duvigneaud, NRRIDRAlAAAB H. Walker, NRRIDSS/SCVB Date: December 5, 2012
M. Sunseri -2 A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely, IRAJ Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482
Enclosures:
- 1. Amendment No. 200 to NPF-42
- 2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsNrrDssStsb Resource LPLIV r/f RidsNrrLAJBurkhardt Resource RidsAcrsAcnw_MailCTR Resource RidsNrrPMWolfCreek Resource RidsNrrDeEicb Resource RidsOgcRp Resource RidsNrrDorlDpr Resource RidsRgn4MailCenter Resource RidsNrrDorlLpl4 Resource HWalker, NRRlDSS/SCVB RidsNrrDraAadb Resource DDuvigneaud, NRRIDRAJAADB RidsNrrDssScvb Resource ADAMS Accession No. ML12318A145 "'via memo dated I OFFICE INRR/DORLlLPL4/PM INRRlDORLlLPL4/LA INRR/DSS/STSB/BC*
NAME FLyon JBurkhardt RElliott DATE 12/3/12 11/14/12 11/21/12 CE NRR/DE/EICB/BC NRRlDSS/SCVB/BC NRR/DRAlAADB/BC NAME JThorpe (DRahn for) RDennig*
DATE 11/19/12 2123112 OFFICE OGC I\ILO RLlLPL4/BC NRR/DORLlLPL4/PM NAME LSubin MMarkley FLyon 12 12/4/12 1215/12 OFFICIAL RECORD COpy