Text

Issuance of Amendment No. 212, Revise Technical Specifications to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation
	ML15169A213
Person / Time
Site:	Wolf Creek
Issue date:	07/28/2015
From:	Lyon C; Plant Licensing Branch IV
To:	Heflin A; Wolf Creek
	Lyon C
References
	TAC MF5280
	Download: ML15169A213 (59)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 28, 2015 Mr. Adam C. Heflin President, Chief Executive Officer, and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - ISSUANCE OF AMENDMENT RE:

ADOPT TSTF-523, REVISION 2, "GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION" (TAC NO. MF5280)

Dear Mr. Heflin:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 212 to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 20, 2014, as supplemented by letters dated March 18 and May 4, 2015.

The amendment revises the TS requirements to address NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in Technical Specification Task Force (TSTF)

Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

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, cJdr Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosures:

1. Amendment No. 212 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. 212 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 November 20, 2014, as supplemented by letters dated March 18 and May 4, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth 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. 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. 212, 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-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: July 28, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 212 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 ii ii 3.4-13 to 3.4-44 3.4-13 to 3.4-45 3.5-4 3.5-4 3.6-17 to 3.6-20 3.6-17 to 3.6-21 3.9-8 3.9-8 3.9-10 3.9-10

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. 212, 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. 212

TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.6 Containment Purge Isolation Instrumentation .......... ........................ 3.3-45 3.3.7 Control Room Emergency Ventilation System (CREVS)

Actuation Instrumentation........................................................... 3.3-49 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation ... ......... .................... ....... ...... ....... ........... ............ 3.3-54 3.4 REACTOR COOLANT SYSTEM (RCS) ................................................... 3.4-1 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits.................................................... 3.4-1 3.4.2 RCS Minimum Temperature for Criticality........................................ 3.4-5 3.4.3 RCS Pressure and Temperature (Pff) Limits.................................. 3.4-6 3.4.4 RCS Loops - MODES 1 and 2 .......................................................... 3.4-8 3.4.5 RCS Loops - MODE 3 ....................................................................... 3.4-9 3.4.6 RCS Loops - MODE 4 ....................................................................... 3.4-12 3.4.7 RCS Loops- MODE 5, Loops Filled ................................................. 3.4-15 3.4.8 RCS Loops - MODE 5, Loops Not Filled.......................................... 3.4-18 3.4.9 Pressurizer........................................................................................ 3.4-20 3.4.10 Pressurizer Safety Valves ................................................................. 3.4-22 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)....................... 3.4-24 3.4.12 Low Temperature Overpressure Protection (LTOP) System........... 3.4-27 3.4.13 RCS Operational LEAKAGE ............................................................. 3.4-32 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage.................................. 3.4-34 3.4.15 RCS Leakage Detection Instrumentation......................................... 3.4-38 3.4.16 RCS Specific Activity......................................................................... 3.4-42 3.4.17 Steam Generator (SG) Tube Integrity ................................................ 3.4-44 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS).............................. 3.5-1 3.5.1 Accumulators .................................................................................... 3.5-1 3.5.2 ECCS - Operating ............................................................................. 3.5-3 3.5.3 ECCS - Shutdown............................................................................. 3.5-6 3.5.4 Refueling Water Storage Tank (RWST)........................................... 3.5-8 3.5.5 Seal Injection Flow ............................................................................ 3.5-10 3.6 CONTAINMENT SYSTEMS ..................................................................... 3.6-1 3.6.1 Containment...................................................................................... 3.6-1 3.6.2 Containment Air Locks...................................................................... 3.6-2 3.6.3 Containment Isolation Valves........................................................... 3.6-7 3.6.4 Containment Pressure...................................................................... 3.6-14 3.6.5 Containment Air Temperature .......................................................... 3.6-15 3.6.6 Containment Spray and Cooling Systems ........................................ 3.6-16 3.6.7 Spray Additive System ....................................................................... 3.6-20 Wolf Creek - Unit 1 ii Amendment No. 123, 131, 157, 164, 167 170, 183,212

RCS Loops - MODE 4 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 ----------~-NOl"E-~~---------

Only required if one RHR loop is OPERABLE.

Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Required loops inoperable. B.1 Suspend operations that Immediately would cause introduction OR into the RCS, coolant with boron concentration less No RCS or RHR loop in than required to meet operation. SOM of LCO 3.1.1.

AND B.2 Initiate action to restore Immediately one loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENl"S SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR or RCS loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.6.2 Verify SG secondary side narrow range water levels 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months are ~ 6% for required RCS loops.

SR 3.4.6.3 Verify correct breaker alignment and indicated power 7 days are available to the required pump that is not in operation.

(continued) I Wolf Creek- Unit 1 3.4-13 Amendment No. 123, 145, 212

RCS Loops - MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.6.4 ---------------NOTE-----------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

Verify required RHR loop locations susceptible to gas 31 days accumulation are sufficiently filled with water.

Wolf Creek - Unit 1 3.4-14 Amendment No. 123, 145, 212

RCS Loops-MODE 5, Loops Filled 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops - MODE 5, Loops Filled LCO 3.4.7 One residual heat removal (RHR) loop shall be OPERABLE and in operation, and either:

a. One additional RHR loop shall be OPERABLE; or

b. The secondary side wide range water level of at least two steam generators (SGs) shall be~ 66%.

~-~~-~~-~-~~~--~~----~-NOT'ES-~~~-~-~~~~---~--~-~-~------

1. The RHR pump of the loop in operation may be removed from operation for :s; 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10°F below saturation temperature.

2. One required RHR loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

3. No reactor coolant pump shall be started with any RCS cold leg temperature :s; 368°F unless the secondary side water temperature of each SG is :s; 50°F above each of the RCS cold leg temperatures.

4. All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation.

APPLICABILIT'Y: MODE 5 with RCS loops filled.

Wolf Creek - Unit 1 3.4-15 Amendment No. 123, 145, 212

RCS Loops-MODE 5, Loops Filled 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore a Immediately second RHR loop to AND OPERABLE status.

Required SGs secondary OR side water levels not within limits. A.2 Initiate action to restore Immediately required SG secondary side water levels to within limits.

B. Required RH R loops B.1 Suspend operations that Immediately inoperable. would cause introduction into the RCS, coolant with OR boron concentration less than required to meet No RHR loop in operation. SOM of LCO 3.1.1.

AND B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Wolf Creek - Unit 1 3.4-16 Amendment No. 123, 145, 212

RCS Loops-MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4. 7 .2 Verify SG secondary side wide range water level is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

~ 66% in required SGs.

SR 3.4.7.3 Verify correct breaker alignment and indicated power 7 days are available to the required RHR pump that is not in operation.

SR 3.4.7.4 Verify required RHR loop locations susceptible to gas 31 days accumulation are sufficiently filled with water.

Wolf Creek - Unit 1 3.4-17 Amendment No.~. 212

RCS loops - MODE 5, loops Not Filled 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS loops - MODE 5, loops Not Filled lCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

NOTES-------------------------------------------

1. All RHR pumps may be removed from operation for :s; 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided:

a. The core outlet temperature is maintained at least 10°F below saturation temperature;

b. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SOM of lCO 3.1.1; and

c. Reactor vessel water level is above the vessel flange.

2. One RHR loop may be inoperable for :s; 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

APPLICABILITY: MODE 5 with RCS loops not filled.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore Immediately RHR loop to OPERABLE status.

(continued)

Wolf Creek - Unit 1 3.4-18 Amendment No. 123, 131, 14a, 1aa, 212

RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

8. Required RHR loops 8.1 Suspend operations that Immediately inoperable. would cause introduction into the RCS, coolant with boron concentration less OR than required to meet the No RHR loop in operation SOM of LCO 3.1.1.

AND 8.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.8.2 Verify correct breaker alignment and indicated power 7 days are available to the required RHR pump that is not in operation.

SR 3.4.8.3 Verify RHR loop locations susceptible to gas 31 days accumulation are sufficiently filled with water.

Wolf Creek - Unit 1 3.4-19 Amendment No. 123, 131, 145, 212

Pressurizer 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Pressurizer LCO 3.4.9 The pressurizer shall be OPERABLE with:

a. Pressurizer water level :-; ; 92%; and

b. Two groups of backup pressurizer heaters OPERABLE with the capacity of each group :?: 150 kW.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressurizer water level not A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months within limit.

AND A.2 Fully insert all rods. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND A.3 Place Rod Control System 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in a condition incapable of rod withdrawal.

AND A.4 Be in MODE4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Wolf Creek - Unit 1 3.4-20 Amendment No. ~.

212

Pressurizer 3.4.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One required group of B.1 Restore required group of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months pressurizer heaters pressurizer heaters to inoperable. OPERABLE status.

c. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition B not AND met.

C.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 Verify pressurizer water level is 5 92%. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.9.2 Verify capacity of each required group of pressurizer 18 months heaters is ;::: 150 kW.

Wolf Creek - Unit 1 3.4-21 Amendment No. 42-3, 212

Pressurizer Safety Valves 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Pressurizer Safety Valves LCO 3.4.1 O Three pressurizer safety valves shall be OPERABLE with lift settings

~ 2411 psig and ~ 2509 psig.

APPLICABILITY: MODES 1, 2, and 3.

NOTE----------------------------

The lift settings are not required to be within the LCO limits during MODE 3 for the purpose of setting the pressurizer safety valves under ambient (hot}

conditions. This exception is allowed for 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months following entry into MODE 3 provided a preliminary cold setting was made prior to heatup.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One pressurizer safety A.1 Restore valve to 15 minutes valve inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND OR B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Two or more pressurizer safety valves inoperable.

Wolf Creek - Unit 1 3.4-22 Amendment No. 12a, 1 aa, 212

Pressurizer Safety Valves 3.4.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify each pressurizer safety valve is OPERABLE in In accordance with accordance with the lnservice Testing Program. the lnservice Following testing, lift settings shall be within +/- 1% of Testing Program 2460 psig.

Wolf Creek - Unit 1 3.4-23 Amendment No. 123, 133, 212

Pressurizer PORVs 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS}

3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE.

APPLICABILITY: MODES 1 and 2, MODE 3 with all RCS cold leg temperatures > 368°F.

ACTIONS

NOTE--------------------------------------

Separate Condition entry is allowed for each PORV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs A.1 Close and maintain power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable and capable of to associated block valve.

being manually cycled.

B. One PORV inoperable and B.1 Close associated block 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months not capable of being valve.

manually cycled.

AND B.2 Remove power from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated block valve.

AND 8.3 Restore PORV to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

(continued)

Wolf Creek - Unit 1 3.4-24 Amendment No. 123, 155, 212

Pressurizer PORVs 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One block valve ------------NOTE-----------

inoperable. Required Actions do not apply when block valve is inoperable solely as a result of complying with Required Actions B.2 or E.2.

C.1 Place associated PORV in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months manual control.

AND C.2 Restore block valve to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A, B, AND or C not met.

D.2 Be in MODE4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. Two PORVs inoperable E.1 Close associated block 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and not capable of being valves.

manually cycled.

AND E.2 Remove power from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated block valves.

AND E.3 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND E.4 Be in MODE4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Wolf Creek - Unit 1 3.4-25 Amendment No. ~.

212

Pressurizer PORVs 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. More than one block valve ----------NOTE----------

inoperable. Required Actions do not apply when block valve is inoperable solely as a result of complying with Required Actions B.2 or E.2.

F.1 Place associated PORVs 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in manual control.

AND F.2 Restore one block valve to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE status.

G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition F not AND met.

G.2 Bein MODE4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 ---------------NOTE----------------

Not required to be performed with block valve closed in accordance with the Required Actions of this LCO.

Perform a complete cycle of each block valve. 92 days SR 3.4.11.2 Perform a complete cycle of each PORV. In accordance with the lnservice Testing Program Wolf Creek - Unit 1 3.4-26 Amendment No . .:t-aa, 212

LTOP System 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP) System LCO 3.4.12 An LTOP System shall be OPERABLE with a maximum of zero safety injection pumps, one Emergency Core Cooling System (ECCS) centrifugal charging pump, and the normal charging pump capable of injecting into the RCS and the accumulators isolated and one of the following pressure relief capabilities:

a. Two power operated relief valves (PORVs) with lift settings within the limits specified in the PTLR, or

b. Two residual heat removal (RHR) suction relief valves with setpoints

~ 436.5 psig and 5 463.5 psig, or

c. One PORV with a lift setting within the limits specified in the PTLR and one RHR suction relief valve with a setpoint ~ 436.5 psig and 5 463.5 psig, or

d. The RCS depressurized and an RCS vent of~ 2.0 square inches.

NOTES---------------------------

1. Two ECCS centrifugal charging pumps may be made capable of injecting for 5 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for pump swap operation.

2. Two safety injection pumps and two ECCS centrifugal charging pumps may be made capable of injecting into the RCS: (a) in MODE 3 with any RCS cold leg temperature 5 368°F and ECCS pumps OPERABLE pursuant to LCO 3.5.2, "ECCS - Operating," and (b) for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entering MODE 4 from MODE 3 or until the temperature of one or more RCS cold leg decreases below 325°F, whichever comes first.

3. One or more safety injection pumps may be made capable of injecting into the RCS in MODES 5 and 6 when the RCS water level is below the top of the reactor vessel flange for the purpose of protecting the decay heat removal function.

4. Accumulator may be unisolated when accumulator pressure is less than the maximum RCS pressure for the existing RCS cold leg temperature allowed by the Prr limit curves provided in the PTLR.

Wolf Creek - Unit 1 3.4-27 Amendment No. 123, 207, 212

LTOP System 3.4.12 APPLICABILITY: MODE 3, with any RCS cold leg temperature~ 368°F, MODE4, MODE 5, MODE 6 when the reactor vessel head is on.

ACTIONS

NOTE---------------------------------

LCO 3.0.4b. is not applicable when entering MODE 4 or MODE 3.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more safety A.1 Initiate action to verify a Immediately injection pumps capable of maximum of zero safety injecting into the RCS. injection pumps are capable of injecting into the RCS.

B. Two ECCS centrifugal B.1 Initiate action to verify a Immediately charging pumps capable of maximum of one ECCS injecting into the RCS. centrifugal charging pump and the normal charging pump capable of injecting into the RCS.

c. An accumulator not C.1 Isolate affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months isolated when the accumulator.

accumulator pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

(continued)

Wolf Creek - Unit 1 3.4-28 Amendment No. 123, 155, 207, 212

LTOP System 3.4.12 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Increase all RCS cold leg 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion temperatures to> 368°F.

Time of Condition C not met. OR D.2 Depressurize affected 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months accumulator to less than the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

E. One required RCS relief E.1 Restore required RCS 7days valve inoperable in MODE relief valve to OPERABLE 3 or MODE 4. status.

F. One required RCS relief F.1 Restore required RCS 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months valve inoperable in relief valve to OPERABLE MODE 5 or6. status.

G. Two required RCS relief G.1 Depressurize RCS and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months valves inoperable. establish RCS vent of

2.0 square inches.

OR Required Action and associated Completion Time of Condition A, B, D, E, or F not met.

OR LTOP System inoperable for any reason other than Condition A, B, C, D, E, or F.

Wolf Creek - Unit 1 3.4-29 Amendment No . .:J-2.3, 212

LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify a maximum of zero safety injection pumps are 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months capable of injecting into the RCS.

SR 3.4.12.2 Verify a maximum of one ECCS centrifugal charging 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months pump and the normal charging pump capable of injecting into the RCS.

SR 3.4.12.3 Verify each accumulator is isolated when 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the PfT limit curves provided in the PTLR.

SR 3.4.12.4 Verify RHR suction isolation valves are open for each 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months required RHR suction relief valve.

SR 3.4.12.5 Verify required RCS vent;;::: 2.0 square inches open. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for vent pathway(s) not locked, sealed or otherwise secured in the open position 31 days for vent valve(s) locked, sealed or otherwise secured in the open position (continued)

Wolf Creek - Unit 1 3.4-30 Amendment No. 123, 2Q7, 212

LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.12.6 Verify PORV block valve is open for each required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months PORV.

SR 3.4.12.7 Not Used.

SR 3.4.12.8 ----------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing any RCS cold leg temperature to :5 368°F.

Perform a COT on each required PORV, excluding 31 days actuation.

SR 3.4.12.9 Perform CHANNEL CALIBRATION for each required 18 months PORV actuation channel.

Wolf Creek - Unit 1 3.4-31 Amendment No. 4-23, 212

RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a. No pressure boundary LEAKAGE;

b. 1 gpm unidentified LEAKAGE;

c. 10 gpm identified LEAKAGE; and

d. 150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RCS operational A.1 Reduce LEAKAGE to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months LEAKAGE not within limits within limits.

for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Pressure boundary LEAKAGE exists.

OR Primary to secondary LEAKAGE not within limit.

Wolf Creek - Unit 1 3.4-32 Amendment No. 123, 164, 212

RCS Operational LEAKAGE 3.4.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 --------------NOTES----------------

1. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

2. Not applicable to primary to secondary LEAKAGE.

Verify RCS operational LEAKAGE is within limits by 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months performance of RCS water inventory balance.

SR 3.4.13.2 -----------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Verify primary to secondary LEAKAGE is ~ 150 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months gallons per day through any one SG.

Wolf Creek - Unit 1 3.4-33 Amendment No. 123, 114, 212

RCS PIV Leakage 3.4.14 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage LCO 3.4.14 Leakage from each RCS PIV shall be within limit.

APPLICABILITY: MODES 1, 2, and 3, MODE 4, except valves in the residual heat removal (RHR) flow path when in, or during the transition to or from, the RHR mode of operation.

ACTIONS

NOTES---------------------------------

1. Separate Condition entry is allowed for each flow path.

2. Enter applicable Conditions and Required Actions for systems made inoperable by an inoperable PIV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more flow paths --------------NOTE----------

with leakage from one or Each valve used to satisfy Required more RCS PIVs not within Action A.1 must have been verified limit. to meet SR 3.4.14.1 and be in the reactor coolant pressure boundary.

A.1 Isolate the high pressure 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months portion of the affected system from the low pressure portion by use of one deactivated remote manual or check valve.

AND A.2. Restore RCS PIV to within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months limits.

(continued)

Wolf Creek - Unit 1 3.4-34 Amendment No. +u, 212

RCS PIV Leakage 3.4.14 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time for Condition A not AND met.

B.2 Bein MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. RHR suction isolation C.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months valve interlock function penetration by use of one inoperable. deactivated remote manual valve.

Wolf Creek - Unit 1 3.4-35 Amendment No.~.

212

RCS PIV Leakage 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1 -------------------NOTES----------------

1. Not required to be performed in MODES 3 and4.

2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.

3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.

Verify leakage from each RCS PIV is equivalent to In accordance with

~ 0.5 gpm per nominal inch of valve size up to a the lnservice maximum of 5 gpm at an RCS pressure ~ 2215 psig Testing Program, and::; 2255 psig. and 18 months Prior to entering MODE2 whenever the unit has been in MODE 5 for 7 days or more, and if leakage testing has not been performed in the previous 9 months Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following check valve actuation due to flow through the valve (continued)

Wolf Creek- Unit 1 3.4-36 Amendment No. ~.

212

RCS PIV Leakage 3.4.14 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.14.2 Verify RHR suction isolation valve interlock prevents 18 months the valves from being opened with a simulated or actual RCS pressure signal ~ 425 psig except when the valves are open to satisfy LCO 3.4.12.

Wolf Creek - Unit 1 3.4-37 Amendment No. ~.

212

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. The containment sump level and flow monitoring system;

b. One containment atmosphere particulate radioactivity monitor; and

c. One containment air cooler condensate monitoring system.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required containment A.1 -------NOTE-------

sump level and flow Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months monitoring system after establishment of inoperable. steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

NOTE-----

The Completion Time is extended beyond the 30 days until startup from a plant shutdown or startup from Refueling Outage 20.

A.2 Restore required 30 days containment sump level and flow monitoring system to OPERABLE status.

(continued)

Wolf Creek - Unit 1 3.4-38 Amendment No. 123, 155, 166, 211, 212

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required containment B.1.1 Analyze samples of the Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months atmosphere particulate containment atmosphere.

radioactivity monitor inoperable. OR 8.1.2 --------NOTE--------

Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND 8.2.1 Restore required 30 days containment atmosphere particulate radioactivity monitor to OPERABLE status.

OR 8.2.2 Verify containment air 30 days cooler condensate monitoring system is OPERABLE.

C. Required containment c. 1 Perform SR 3.4.15.1. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months cooler condensate monitoring system OR inoperable.

C.2 ----------NOTE-----------

Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Perform SR 3.4.13.1.

(continued)

Wolf Creek - Unit 1 Amendment No. 123, 1Se, 212

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required containment D.1 Restore required 30 days atmosphere particulate containment atmosphere radioactivity monitor particulate radioactivity inoperable. monitor to OPERABLE status.

AND OR Required containment cooler condensate D.2 Restore required 30 days monitoring system containment cooler inoperable. condensate monitoring system to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND E.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. All required monitoring F.1 Enter LCO 3.0.3. Immediately methods inoperable.

Wolf Creek - Unit 1 3.4-40 Amendment No. 123, 166, 212

RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment atmosphere particulate radioactivity monitor.

SR 3.4.15.2 Perform COT of the required containment 92 days atmosphere particulate radioactivity monitor.

SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required 18 months containment sump level and flow monitoring system.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of the required 18 months containment atmosphere particulate radioactivity monitor.

SR 3.4.15.5 Perform CHANNEL CALIBRATION of the required 18 months containment cooler condensate monitoring system.

Wolf Creek - Unit 1 3.4-41 Amendment No. 123, 166, 212

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT 1-131 ------------NOTE----------

not within limit. LCO 3.0.4c. is applicable.

A.1 Verify DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EQUIVALENT 1-131

5 60 µCi/gm.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT 1-131 to within limit.

B. DOSE EQUIVALENT ------------NOTE----------

XE-133 not within limit. LCO 3.0.4c. is applicable.

8.1 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT XE-133 to within limit.

(continued)

Wolf Creek - Unit 1 3.4-42 Amendment No. 123, 155, 170, 212

RCS Specific Activity 3.4.16 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met.

C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR DOSE EQUIVALENT 1-131

> 60 µCi/gm.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 -~-~~---------~----~---NOTE----~-~~---------~-~~-----~-

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT XE-133 7 days specific activity :s; 500 µCi/gm.

SR 3.4.16.2 ----~-~--------~~--~NOTE-------~----~-----~-~-~-------

Only required to be performed in MODE 1.

14 days Verify reactor coolant DOSE EQUIVALENT 1-131 AND specific activity :s; 1.0 µCi/gm.

Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of~ 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period Wolf Creek - Unit 1 3.4-43 Amendment No. 123, 170, 212

SG Tube Integrity 3.4.17 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.17 Steam Generator (SG) Tube Integrity LCO 3.4.17 SG tube integrity shall be maintained.

All SG tubes satisfying the tube plugging criteria shall be plugged in accordance with the Steam Generator Program.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

NOTE---------------------------------

Separate Condition entry is allowed for each SG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SG tubes A.1 Verify tube integrity of the 7 days satisfying the tube plugging affected tube(s) is criteria and not plugged in maintained until the next accordance with the Steam refueling outage or SG Generator Program. tube inspection.

AND A.2 Plug the affected tube(s) in Prior to entering accordance with the Steam MODE 4 following Generator Program. the next refueling outage or SG tube inspection B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR SG tube integrity not maintained.

Wolf Creek - Unit 1 3.4-44 Amendment No.164, 17Q, 199, 212

SG Tube Integrity 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify SG tube integrity in accordance with the In accordance Steam Generator Program. with the Steam Generator Program SR 3.4.17.2 Verify that each inspected SG tube that satisfies the Prior to entering tube plugging criteria is plugged in accordance with MODE 4 following the Steam Generator Program. a SG tube inspection Wolf Creek - Unit 1 3.4-45 Amendment No. 164, 170, 1QQ, 212

ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify the following valves are in the listed position 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with power to the valve operator removed.

Number Position Function 8N HV-8813 Open Safety Injection to RWST Isolation Valve EM HV-8802A Closed SI Hot Legs 2 & 3 Isolation Valve EM HV-88028 Closed SI Hot Legs 1 & 4 Isolation Valve EM HV-8835 Open Safety Injection Cold Leg Isolation Valve EJ HV-8840 Closed RHR/SI Hot Leg Recirc Isolation Valve EJ HV-8809A Open RHR to Accum Inject Loops 1 & 2 Isolation Valve EJ HV-88098 Open RHR to Accum Inject Loops 3 & 4 Isolation Valve SR 3.5.2.2 -------NOTE ----

Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS manual, power operated, and 31 days automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.3 Verify ECCS locations susceptible to gas 92 days accumulation are sufficiently filled with water.

SR 3.5.2.4 Verify each ECCS pump's developed head at the test In accordance with flow point is greater than or equal to the required the lnservice developed head. Testing Program (continued)

Wolf Creek - Unit 1 3.5-4 Amendment No.~. 212

Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two containment cooling D.1 Restore one containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months trains inoperable. cooling train to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C or D AND not met.

E.2 Bein MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two containment spray F.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more trains inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 --------NOTE--------

Not required to be met for system vent flow paths opened under administrative control.

Verify each containment spray manual, power 31 day operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

(continued)

Wolf Creek - Unit 1 3.6-17 Amendment No. 123, 167, 212

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.6.2 Operate each containment cooling train fan unit for 31 days

~ 15 minutes.

SR 3.6.6.3 Not Used.

SR 3.6.6.4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equal to the lnservice the required developed head. Testing Program SR 3.6.6.5 Verify each automatic containment spray valve in the 18 months flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.6.6.6 Verify each containment spray pump starts 18 months automatically on an actual or simulated actuation signal.

SR 3.6.6.7 Verify each containment cooling train starts 18 months automatically and minimum cooling water flow rate is established on an actual or simulated actuation signal.

SR 3.6.6.8 Verify each spray nozzle is unobstructed. Following maintenance which could result in nozzle blockage Wolf Creek - Unit 1 3.6-18 Amendment No. 123, 167, 203, 212

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.6.6.9 Verify containment spray locations susceptible to gas 92 days accumulation are sufficiently filled with water.

Wolf Creek - Unit 1 3.6-19 Amendment No.123, 1e7, 203, 212

Spray Additive System 3.6.7 3.6 CONTAINMENT SYSTEMS 3.6.7 Spray Additive System LCO 3.6.7 The Spray Additive System shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Spray Additive System A.1 Restore Spray Additive 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. System to OPERABLE status.

B. Required Action and 8.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND 8.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify each spray additive manual, power operated, 31 days and automatic valve in the flow path that is not locked, sealed, or otheiwise secured in position is in the correct position.

(continued)

Wolf Creek - Unit 1 3.6-20 Amendment No. 123, 167, 212

Spray Additive System 3.6.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.7.2 Verify spray additive tank solution volume is ~ 4340 184 days gal and ~ 4540 gal.

SR 3.6.7.3 Verify spray additive tank solution concentration is 184 days

~ 28% and ~ 31 % by weight.

SR 3.6.7.4 Verify each spray additive automatic valve in the flow 18 months path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.6.7.5 Verify spray additive flow rate from each solution's 5 years flow path.

Wolf Creek - Unit 1 3.6-21 Amendment No. 123, 197, 212

RHR and Coolant Circulation - High Water Level 3.9.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months reactor coolant at a flow rate of~ 1000 gpm.

SR 3.9.5.2 Verify required RHR loop locations susceptible to gas 31 days accumulation are sufficiently filled with water.

Wolf Creek- Unit 1 3.9-8 Amendment No. 4-23, 212

RHR and Coolant Circulation - Low Water Level 3.9.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Initiate action to restore Immediately one RHR loop to operation.

AND B.3 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months reactor coolant at a flow rate of~ 1000 gpm.

SR 3.9.6.2 Verify correct breaker alignment and indicated power 7 days available to the required RHR pump that is not in operation.

SR 3.9.6.3 Verify RHR loop locations susceptible to gas 31 days accumulation are sufficiently filled with water.

Wolf Creek- Unit 1 3.9-10 Amendment No.~. 212

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 212 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 November 20, 2014, as supplemented by letters dated March 18 and May 4, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML14330A247, ML15084A104, and ML15132A651, respectively), Wolf Creek Nuclear Operating Corporation (WCNOC, the licensee) requested changes to the Technical Specifications (TSs) for Wolf Creek Generating Station (WCGS). The supplemental letters dated March 18 and May 4, 2015, 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) staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 31, 2015 (80 FR 17105).

The proposed changes would revise the TS requirements to address NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in Technical Specification Task Force (TSTF)

Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" (ADAMS Accession No. ML13053A075). WCNOC's application was consistent with the NRG-approved safety evaluation for TSTF-523, Revision 2, as published in the Notice of Availability in the Federal Register on January 15, 2014 (79 FR 2700), "TSTF-523, 'Generic Letter 2008-01, Managing Gas Accumulation,' Using the Consolidated Line Item Improvement Process," with the exception of a proposed surveillance requirement (SR) frequency.

Specifically, WCNOC proposed a surveillance frequency of 92 days for the modified SR 3.5.2.3, "Verify ECCS (Emergency Core Cooling System) locations susceptible to gas accumulation are sufficiently filled with water." WCNOC also proposed adding a new SR 3.6.6.9, "Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water,"

with a frequency of 92 days. These SR frequencies differ from with the 31-day frequency that was specified in TSTF-523, Revision 2.

Enclosure 2

Plants typically are designed and licensed so that systems, such as the ECCS and the residual heat removal system (RHR), are to be in a water-solid condition. Consequently, for most licensees, including WCNOC, whether stated or not, the current design basis for the subject systems is a water-solid condition. This was reiterated in Nuclear Energy Institute (NEI) 09-10, Revision 1a-A, "Guidelines for Effective Prevention and Management of System Gas Accumulation," April 2013 (ADAMS Accession No. ML13136A129), which states, in part, that "If there is no specified design limit, then the design limit is no gas present." This means the subject systems must be water-solid when transitioning from an outage into power operation.

Once the transition is complete, voids are acceptable in recognition of the possibility that voids may form during operation provided operability is reasonably maintained and the voids are removed as soon as is practical. This is consistent with the NRC staff's position in "Task Interface Agreement - Emergency Core Cooling Systems (ECCS) Voiding Relative to Compliance with Surveillance Requirements (SR) 3.0.1.1, 3.5.2.3, and 3.5.3.1 (TIA 2008-03),"

dated October 21, 2008 (ADAMS Accession No. ML082560209), which stated that system piping can be considered filled with water if system operability has been established.

2.0 REGULATORY EVALUATION

2.1 Background

Gas accumulation in reactor systems can result in water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel. These effects may result in the subject system being unable to perform its specified safety function. The NRC issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," in January 2008 to address the issue of gas accumulation in ECCS, OHR, and CS systems (ADAMS Accession No. ML072910759). The industry and NRC staff agreed that a change to the Standard Technical Specifications and plant-specific TS would be necessary to address some issues discussed in GL 2008-01. TSTF-523 contains changes to the TS SRs and TS Bases to address some of the concerns in GL 2008-01. The licensee proposed amending the WCGS TS using a plant-specific adoption of the TSTF-523 changes.

2.2 Technical Specification Changes Changes were proposed for SRs 3.5.2.2, 3.5.2.3, 3.6.6.1, as well as the addition of new SRs 3.4.6.4, 3.4.7.4, 3.4.8.3, 3.6.6.9, 3.9.5.2, and 3.9.6.3 to TS 3.4.6, "RCS Loops - MODE 4," TS 3.4. 7, "RCS Loops - MODE 5, Loops Filled," TS 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," TS 3.5.2, "ECCS - Operating," TS 3.6.6, "Containment Spray and Cooling Systems," TS 3.9.5, "RHR and Coolant Circulation - High Water Level," and TS 3.9.6, "RHR and Coolant Circulation - Low Water Level," respectively.

The licensee proposed a variation in the numbering scheme from that provided in TSTF-523.

The licensee proposed the addition of SR 3.6.6.9 to TS 3.6.6, whereas the TSTF inserted the corresponding SR as 3.6.6.A.4 and renumbers the remaining SRs accordingly. This change is administrative in nature.

2.3 Regulatory Review The regulations in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 provide general design requirements for nuclear power plants. As documented in the WCGS Updated Safety Analysis Report, Section 3.1, WCGS is designed in accordance with Appendix A. Appendix B to 10 CFR Part 50, the TSs, and the licensee quality assurance programs provide operating requirements. The regulatory requirements of 10 CFR Part 50, Appendix A, that are applicable to gas management in the subject systems include: General Design Criteria (GDC) 1, 34, 35, 36, 37, 38, 39 and 40. GDC 1 requires that structures, systems and components (SSCs) be designed, fabricated, erected, and tested to quality standards commensurate with their importance to safety. GDC 34 requires an RHR system designed to maintain specified acceptable fuel design limits and to meet design conditions that are not exceeded if a single failure occurs and specified electrical power systems fail. GDC 35, 36, and 37 require an ECCS design that meets performance, inspection, and testing requirements.

Additionally, the regulations in 10 CFR 50.46 provide specified ECCS performance criteria.

GDC 38, 39, and 40 require a containment heat removal system design that meets performance, inspection, and testing requirements.

Quality assurance criteria provided in 10 CFR Part 50, Appendix B, that apply to gas management in the subject systems include: Criteria Ill, V, XI, XVI, and XVII. Criteria Ill and V require measures to ensure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, "Definitions," and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion XI requires a test program to ensure that the subject systems will perform satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have been satisfied. Criterion XVI requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management.

Criterion XVII requires maintenance of records of activities affecting quality.

The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36(c). The regulations at 10 CFR 50.36 require that the TSs include items in the following categories: ( 1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCO); (3) SRs; (4) design features; and (5) administrative controls. SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. Typically, TS Section 5 requires that licensees establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)." Appendix A to RG 1.33 identifies instructions for filling and venting the ECCS and DHR system, as well as for draining and refilling heat exchangers. Standard TSs and most licensee TSs include SRs to verify that at least some of the subject systems piping is filled with water.

The NRC's guidance for the format and content of licensee TSs can be found in NUREG-1431, "Standard Technical Specifications Westinghouse Plants".

Regulatory guidance for the NRC staff's review of containment heat removal systems, ECCS, and RHR systems is provided in the following revisions and sections of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR Edition" (SRP).

Revision 3 of SRP, Section 6.2.2, "Containment Heat Removal Systems," March 2007 (ADAMS Accession No. ML070160661), provides the procedures concerning the review of containment heat removal under post-accident conditions to help ensure compliance with GDC 38, 39, and 40.

Revision 3 of SRP, Section 6.3, "Emergency Core Cooling System," March 2007 (ADAMS Accession No. ML070550068), provides the procedures concerning the review of ECCS to help ensure compliance with GDC 35, 36, and 37.

Revision 5 of SRP, Section 5.4.7, "Residual Heat Removal (RHR) System," May 2010 (ADAMS Accession Number ML100680577), provides the procedures concerning the review of RHR system as it is used to cool the reactor coolant system (RCS) during and following shutdown to help ensure compliance with GDC 34.

3.0 TECHNICAL EVALUATION

The proposed change adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1431, "Standard Technical Specifications Westinghouse Plants, by TSTF-523.

The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36(c).

3.1 Licensee's Proposed TS Changes TS Table of Contents The starting page numbers were adjusted for the following TS entries on the table of contents, page ii:

3.4.8 - RCS Loops - MODE 5, Loops Not Filled 3.4.9 - Pressurizer 3.4.10 - Pressurizer Safety Valves 3.4.11 - Pressurizer Power Operated Relief Valves (PORVs) 3.4.12 - Low Temperature Overpressure Protection (LTOP) System 3.4.13 - RCS Operational LEAKAGE 3.4.14 - RCS Pressure Isolation Valve (PIV) Leakage 3.4.15 - RCS Leakage Detection Instrumentation 3.4.16 - RCS Specific Activity 3.4.17 - Steam Generator (SG) Tube Integrity 3.6.7 - Spray Additive System

TS 3.4.6 - RCS Loops - MODE 4 New SR 3.4.6.4, with a surveillance frequency of "31 days," would state:

NOTE-------------------------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

TS 3.4. 7 - RCS Loops - MODE 5, Loops Filled New SR 3.4.7.4, with a surveillance frequency of "31 days," would state:

Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

TS 3.4.8 - RCS Loops - MODE 5, Loops Not Filled New SR 3.4.8.3, with a surveillance frequency of "31 days," would state:

Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

TS 3.5.2 - ECCS - Operating Current SR 3.5.2.2 would be revised to add the following Note:

NOTE-------------------------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Current SR 3.5.2.3 states:

Verify ECCS piping is full of water.

Revised SR 3.5.2.3 would state:

Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water.

In addition, the current SR 3.5.2.3 frequency of "31 days" would be changed to "92 days."

TS 3.6.6 - Containment Spray and Cooling Systems Current SR 3.6.6.1 would be revised to add the following Note:

N 0 TE-------------------------------------------------

Not required to be met for system vent flow paths opened under administrative control.

New SR 3.6.6.9, with a surveillance frequency of "92 days, would state:

Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water.

TS 3.9.5 - RHR and Coolant Circulation - High Water Level New SR 3.9.5.2, with a surveillance frequency of "31 days, would state:

Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

TS 3.9.6- RHR and Coolant Circulation - Low Water Level New SR 3.9.6.3, with a surveillance frequency of "31 days," would state:

Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

3.2 NRC Staff Evaluation The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRC discussion contained in Task Interface Agreement (TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative To Compliance With Surveillance Requirements (SR) 3.5.1.1, 3.5.2.3, and 3.5.3.1" (ADAMS Accession No. ML082560209). Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRC stated that the intent of the TS SRs, which state "full of water," may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function. Therefore the phrase, "sufficiently filled with water" was recommended for the proposed TS changes. In the TS, "sufficiently filled with water" is understood to mean "sufficiently filled with water to support Operability." The regulation at 10 CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language, "Verify the [system name]

locations susceptible to gas accumulation are sufficiently filled with water," is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that state that the SR does not have to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering Mode 4 for pressurized water reactors is acceptable because the note provides a

limited time to perform the Surveillance after entering the Applicability of the LCO; however, under the STS usage rules (STS Section 1.4), the requirement to manage gas accumulation is not affected. Licensees must have confidence that the SR can be met or the LCO must be declared not met.

The language for the notes that allow the SRs to not be met for system vent flow paths opened under administrative control is necessary to allow the licensee to credit administratively controlled manual action to close the system vent flow path in order to maintain system Operability during system venting and performance of the proposed gas accumulation SR.

Therefore, these notes are acceptable.

The NRC staff found that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCO will be met.

WCNOC's November 20, 2014, license amendment request (LAR) is inconsistent with TSTF-523, Revision 2 in that for certain SRs, WCNOC proposes a 92 day frequency instead of a 31 day frequency. Specifically, WCNOC proposed a surveillance frequency of 92 days for the modified SR 3.5.2.3, "Verify ECCS (Emergency Core Cooling System) locations susceptible to gas accumulation are sufficiently filled with water." WCNOC also proposed adding a new SR 3.6.6.9, "Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of 92 days. WCNOC justified the proposed SR frequencies as follows:

Potential leakage from the accumulators into the ECCS is continuously monitored.

Volume control tank pressure is monitored to address potential gas formation in the centrifugal charging pump suctions.

RCS leakage is addressed by performance of an RCS inventory balance every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (SR 3.4.14.1)

RCS leakage into containment is addressed by monitoring containment sump level, containment radioactivity, and containment cooling equipment.

RCS leakage into the ECCS and/or the RHR system is detected by an increase in system pressure. RHR system pressure is recorded once per shift.

The WCGS design basis for the ECCS and containment spray system is "no gas" with the exception of core spray discharge piping inside containment. There are 123 vent locations and 113 are vented followed by ultrasonic test (UT) to verify that the "water-solid" condition has been restored. UT is not qualified for ten of the locations. These are vented until a solid stream of water issues from the vent valve.

WCNOC stated in its application that its surveillance procedures require documenting whether a void or a water solid condition is found in the ECCS during performance of the SR. The licensee identified all instances of discovering a void during SRs performed during Cycles 17

through 20. In all instances, the licensee stated that a water solid condition was restored immediately or within a reasonable time from discovery of a void in the ECCS.

The licensee provided the following monitoring history in its letter dated May 4, 2015:

Cycle Total locations monitored 17 1680 18 2331 19 2784 20 2328 (through 08/05/2014)

The licensee provided the following void discoveries applicable to SR 3.5.2.3 and 3.6.6.9 in its letter dated May 4, 2015:

Approximate Days Since Last Listed Surveillance I TS Void I Surveillance Cycle Location Allowable As left Frequency Comments 16 (1 ) See -- See -- Nine during refueling outage and startup. Seven comments comments left water-solid. One not vented (< 0.001 ft 3 with 0.25 ft 3 allowed). One partly vented (to <<

allowable 0.25 ft 3).

17 EJV0128 <<0.25 / 0.25 Solid 6 / 31 Increased surveillance during startup.

17 EVJ0223 0.13 / 0 Solid 17 / 31 Increased surveillance after startup.

17 EVJ0128 <<0.25 / 0.25 Solid 12 / 31 Source was degassing. Increased surveillance after startup.

17 EVJ0128 <<0.25 I 0.25 Solid 4 / 31 Source was degassing. Increased surveillance after startup.

17 EVJ0203 <<0.25 / 0.25 Solid -21 / 31 Source was degassing. Increased surveillance after startup.

17 EMV02547 <<0.25 I 0.25 Solid 31/31 Leftover air from pre-startup.

17 ENV0117 -0.006 See 31 / 31 Small void after venting. Water-solid 6 days later.

comments 17 (1) -- -- Solid -- Two during refueling outage and startup.

18 EJV0088 2.4 Solid 31 / 31 Follow-up concluded operability retained.

18 EJV0088 0.03 Solid 8 / 31 Follow-up for previous void.

18 EJV0088 0.02 Solid 7 / 31 Follow-up for previous void.

18 -- -- See Abnormal RHR Eleven voids from RHR heat exchanger. Three comments pump behavior vented to small void, 3 to solid. One not vented; over 2 days and void gone in 2 days. One vented to small void; over a day during gone next day. Two exceeded acceptance criteria.

vacuum fill and Allowable heat exchanger void volume not vent 50 days later I determined; 6.2 ft3 not swept out but later removed 31 by vacuum fill and vent during an outage.

Reasonable assurance stated that systems would have performed safety functions.

18 EJV0088 0.5 Solid - / 31 Follow-up from accumulator level loss.

Approximate Days Since Last Listed Surveillance I TS Void I Surveillance Cycle Location Allowable As left Frequency Comments 18 EJV0223 <0.001/0 Solid 31/31 18 BGV0496 0.04 Solid 31 / 31 18 ENV0117 6 See 92 / 92 Inoperable. Void vented to half of criterion.

comments Water-solid next day.

18 ENV0093 0.02 See 92 / 92 Small void remained. Water-solid 4 days later.

comments 18 ENV0093 <0.004 See 27 / 92 Could not be vented. Water-solid 36 days later.

comments 19 ENV0120 1.1 Solid 92 / 92 Post discovery determined operability not lost.

19 ENV0120 0.28 Solid 44 /92 19 EJV0088 >0.59 / 0.59 Solid 6 hrs/ 31 Accumulator level loss.

19 EJV0088 -1.12 max I Solid See comments I 31 Three instances over 9 days due to RCS leakage.

0.59 Last one exceeded criterion; follow-up led to conclusion that safety function was not lost.

19 EJV0088 0.2 Solid 15 / 31 RCS leakage.

19 EJV0088 0.005 Solid 7 / 31 RCS leakage.

19 EMV0259 0.02 Solid 31 / 31 19 EMV0058 0.04 See NA Post fill and vent following outage. Could not be comments vented. Water-solid a month later.

19 (1) EMV0117 0.002 Solid NA Post fill and vent.

20 EMV0257 8 Solid NA Post fill and vent.

(1) Includes refueling outage at end of cycle.

In general, the water-solid criterion was restored whenever gas was found. This is consistent with the NRC staff approach that the water-solid condition should be restored at the earliest practical time following discovery of gas in applicable system piping. Multiple void discoveries during and immediately following an outage are an indication of assessing previous void removal actions. Discoveries following observed accumulator and RCS behavior show follow-up that does not depend on previously specified surveillances. The RHR pump abnormal behavior associated with the Cycle 18 EJV0088 void was not discovered by a 31-day SR and would not have been found by a 92-day SR. Eliminating these occurrences, the following remain:

Approximate Days Since Last Listed Surveillance I TS Void/ Surveillance Cycle Location Date Allowable Frequency Comments 18 EJV0088 04/14/10 2.4 31 I 31 Follow-up concluded operability retained. If void continued to grow at rate consistent with the 31-day surveillance, operability may have been lost with a 92-day SR.

18 ENV0117 07/06/10 6 92 I 92 Inoperable. Earlier surveillance may have prevented loss of operability.

19 ENV0120 12/03/12 1.1 92 I 92 Follow-up concluded operability retained.

The two most challenging cases with respect to a 92-day SR occurred 5 years ago. WCNOC stated that the one that occurred 3 years ago did not cause a loss of operability.

The licensee's 7-year history of 9123 surveillances involving 123 vent locations yielded 53 void discoveries, many associated with follow-up after an outage before returning to power that are not an operability concern. Voids would be expected to continue to be found in the same manner with the 92-day SR frequency. Some of the remaining voids were discovered by monitoring such indications as accumulator level and RCS leakage. Most of the remaining voids that were discovered by periodic monitoring were so small as not to be of an operability concern. Three voids failed to meet acceptance criteria, two of which challenged operability and occurred 5 years ago. The void discovery history established that the licensee has procedures in place that supplement periodic void monitoring surveillances to address potential void generation, such as accumulator level, RCS leakage, and startup monitoring.

In consideration of the above, the NRC staff concludes that a 92-day surveillance frequency for SRs 3.5.2.3 and 3.6.6.9 is acceptable. The intent of the TS SRs is met if the licensee can establish, through an Operability Determination, 1 that there is a reasonable expectation that the system in question will perform its specified safety function. The regulation at 10 CFR 50.36(c)(3) states that one of the purposes of the SRs is to assure that LCOs are met.

Therefore, the new SR language is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable. The NRC staff concludes that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCOs will be met.

Additionally, for the reasons discussed earlier, the proposed changes to the TSs to adopt TSTF-523, Revision 2, are acceptable to the NRC staff.

1 NRC Inspection Manual Chapter 0326, "Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety," January 31, 2014 (ADAMS Accession No. ML13274A578).

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, and involve changes to SRs. The NRG 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 March 31, 2015 (80 FR 17105). Accordingly, the amendment meets the eligibility 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: W. Lyon, NRR/DSS/SRXB M. Chernoff, NRR/DSS/STSB Date: July 28, 2015

ML15169A213 *via memo dated OFFICE NRR/DORL/LPL4-1 /PM NRR/DORL/LPL4-1 /LA NRR/DSS/STSB/BC NRR/DSS/SRXB/BC NAME FL yon JBurkhardt RElliott CJackson*

DATE 6/29/15 6/23/15 7/14/15 6/9/15 OFFICE OGC-NLO NRR/DORL/LPL4-1 /BC NRR/DORL/LPL4-1/PM NAME JLindell (with comments) MMarkley FLyon DATE 7/24/15 7/28/15 7/28/15

v t e Letter Sequence Approval
TAC:MF5280, Generic Letter 2008-01, Managing Gas Accumulation (Approved, Closed)
Initiation Request, Request Acceptance Administration Questions 9 February 2015 10 February 2015 27 March 2015 Answers 18 March 2015 Results Approval Other:
MONTHYEAR2015-02-09 [Table View]

ML15169A213

Text

SUBJECT:

Dear Mr. Heflin:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.1 Background

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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