Text

License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C)System
	ML17186A082
Person / Time
Site:	Wolf Creek
Issue date:	06/28/2017
From:	Mccoy J; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17186A061	List: ET 17-0010, License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C)System;
References
	ET 17-0010
	Download: ML17186A082 (69)
	v • d • e

Security-Related Information -Withhold Under 10 CFR 2.390 WM.FCREEK

'NUCLEAR OPERATING CORPORATION Jaime H. McCoy Vice President Engineering U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 June 28, 2017 ET 17-0010

Reference:

NRC letter dated September 1, 2016, "Summary of August 25, 2016, Public Meeting with Wolf Creek Nuclear Operating Corporation and AmerenUE Regarding a Proposed Application for a New Technical Specification for the Class 1 E Electrical Equipment Air Conditioning System (CAC Nos MF8118 and MF8119)"

Subject:

Docket No. 50-482: License Amendment Request for Addition of New Technical Specification 3.7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System" To Whom It May Concern:

Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS) to incorporate a new specification into the WCGS Technical Specifications (TS). The proposed amendment would add new TS 3. 7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System," to the WCGS TSs.

New TS 3.7.20 will include the Limiting Condition for Operation (LCO) statement, Applicability during which the LCO must be met, ACTIONS (with Conditions, Required Actions, and Completion Times) to be applied when the LCO is not met, and Surveillance Requirements (with a specified Frequency) to demonstrate that the LCO is met for the Class 1 E electrical equipment A/C trains at WCGS.

NOTE: ATTACHMENT I CONTAINS SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION; UPON 18£13\\AFM. Ttol!<Ji9fdrlJ&l<B@WRh~T(f:SR34SSOOCONTROLLED.

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ET 17-0010 Page 2 of 4 Security-Related Information - Withhold Under 10 CFR 2.390 The application of the TS definition of OPERABILITY requires that associated electrical TS LCOs be declared not met upon the determination of a Class 1 E electrical equipment A/C train being nonfunctional, is overly restrictive and does not provide sufficient opportunity to restore the Class 1 E electrical equipment NC train to a FUNCTIONAL status resulting in an unnecessary plant shutdown. Adding new TS 3.7.20 for the support system function performed by the Class 1 E electrical equipment NC trains allows LCO 3.0.6 to be applied such that support system inoperability is dealt within the Conditions and Required Actions of TS 3.7.20.

Planned modifications would allow one Class 1 E electrical equipment A/C train to provide adequate area cooling for both trains of Class 1 E electrical equipment during normal and accident conditions while minimizing mitigating actions.

Attachments I through VI provide the Evaluation, Evaluation (Redacted), Markup of TSs, Retyped TS pages, proposed TS Bases changes, and list of regulatory commitments, respectively, in support of this amendment request. Attachment V is provided for information only. Final TS Bases changes will be implemented pursuant to TS 5.5.14, "Technical Specification (TS) Bases Control Program," at the time the amendment is implemented.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." Pursuant to 1 O CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Section (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

Attachment I to this letter contains security-related information which could reasonably expected to be useful to potential adversaries. WCNOC requests that Attachment I be withheld from public disclosure in accordance with 10 CFR 2.390. Attachment II provides a redacted version of Attachment I.

This amendment application was reviewed by the Plant Safety Review Committee. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," Section (b)(1 ), a copy of this amendment application, with Attachments II through VI, is being provided to the designated Kansas State official.

On August 25, 2016, WCNOC and Callaway Plant personnel conducted a pre-application meeting with the Nuclear Regulatory Commission (NRC) staff to provide advance notification of plans to prepare and submit a license amendment request to add new TS 3.7.20.

The Reference documents the results of the August 25, 2016 pre-application meeting.

WCNOC requests approval of this license amendment request by July 30, 2018. The license amendment is not required for implementation during a refueling outage. It is anticipated that the planned modifications discussed in Attachment I will be completed during the Spring 2018 Refueling Outage. The license amendment, as approved, will be effective upon issuance and will be implemented within 90 days from the date of issuance.

NOTE: ATTACHMENT I CONTAINS SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION; UPON SEPARATION THIS COVER LETTER IS DECONTROLLED.

Security-Related Information - Withhold Under 10 CFR 2.390 ET 17-0010 Page 3 of 4 Attachment VI contains a list of regulatory commitments.

The modifications proposed by regulatory commitment will be implemented under the requirements of 10 CFR 50.59 and it is expected that NRC approval will not be required. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Cynthia R. Hafenstine at (620) 364-4204.

Sincerely,

JHM/rlt Attachments: I Evaluation Evaluation (Redacted)

II 111 IV v

VI Proposed Technical Specification Changes (Mark-up)

Revised Technical Specification Pages Proposed TS Bases Changes (for information only)

List of Regulatory Commitments cc:

K. M. Kennedy, (NRC), w/a B. K. Singal (NRC), w/a K. S. Steves (KDHE), w/a (except Attachment I)

N. H. Taylor (NRC), w/a Senior Resident Inspector (NRC), w/a NOTE: ATTACHMENT I CONTAINS SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION; UPON SEPARATION THIS COVER LETTER IS DECONTROLLED.

Security-Related Information - Withhold Under 10 CFR 2.390 ET 17-0010 Page 4of4 STATE OF KANSAS COUNTY OF COFFEY SS Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

J-Jm By~~~-r-;;._...:......-=-~~~~~~~-11-~~~~

Jamie H.

cCoy Vice Pre ident Engineering

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SUBSCRIBED and sworn to before me this 2 ~ -z..day of ~

UJl -e......

GAYLE SHEPHEARD My Appointment Expires July 24, 2019

'2017.

Expiration Date _/j_Q)__.tf

........ /_d_O_)_g __

NOTE: ATTACHMENT I CONTAINS SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION; UPON SEPARATION THIS COVER LEITER IS DECONTROLLED.

Seourity Related Information

'Nithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 ATTACHMENT II Redacted

Security RelateEI Information

'PJithholEI UnEler 10 CFR 2.390 Attachment II to ET 17-0010 Page 1of48 EVALUATION OF THE PROPOSED CHANGE

Subject:

Application for License Amendment for the Addition of New Technical Specification

3. 7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Proposed Technical Specification Changes 2.2

System Description

2.3 Equipment Reliability 2.4 Need for Change

3.0 TECHNICAL EVALUATION

3.1 Normal and Design Basis Accident Environmental Conditions 3.2 Single Train Operation Calculation 3.3 Fire Protection 3.4 Operator Actions 3.5 Planned Modifications 3.6 Proposed Technical Specifications

3. 7 Differences from the Callaway Plant

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Seourity Related Information

'NithholEI UnEler 10 CFR 2.390 Attachment II to ET 17-0010 Page 2of48 EVALUATION 1.0

SUMMARY

DESCRIPTION The proposed amendment would add new Technical Specification (TS) 3.7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System," to the Wolf Creek Generating Station (WCGS) TSs. New TS 3.7.20 will include the Limiting Condition for Operation (LCO) statement, Applicability during which the LCO must be met, ACTIONS (with Conditions, Required Actions, and Completion Times) to be applied when the LCO is not met, and Surveillance Requirements (SR) with a specified Frequency to demonstrate that the LCO is met for the Class 1 E Electrical Equipment A/C System trains at WCGS. Additionally, TS Table of Contents page iii is revised to reflect the incorporation of new TS 3.7.20.

The application of the TS definition of OPERABILITY requires that associated electrical TS LCOs be declared not met upon the determination of a Class 1 E electrical equipment A/C train being nonfunctional, is overly restrictive and does not provide sufficient opportunity to restore the Class 1 E electrical equipment A/C train to a functional status resulting in an unnecessary plant shutdown. The requirements of TS 3.7.20 in conjunction with planned modifications would allow one OPERABLE Class 1 E electrical equipment A/C train to provide adequate area cooling for both trains of Class 1 E electrical equipment during normal and accident conditions (with minimal mitigating actions being required).

The proposed TSs in conjunction with planned modifications will minimize challenges to plant systems and the plant operators, facilitate maintenance activities, as well as enhancing plant safety.

2.0 DETAILED DESCRIPTION 2.2 Proposed Technical Specification Changes The proposed amendment adds new TS 3.7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System," with requirements established for the Class 1 E Electrical Equipment A/C System trains (including A/C units SGK05A/B). The TS markups and retyped pages are provided in Attachments Ill and IV, respectively. Corresponding TS Bases are provided in Attachment V (for information only).

The new LCO specifies that two Class 1 E electrical equipment A/C trains be OPERABLE. The LCO Applicability would include MODES 1, 2, 3, and 4. The Applicability for this new support system LCO reflects the Applicability of TS 3.7.8, "Essential Service Water (ESW) System," the heat sink for the Class 1 E electrical equipment A/C trains during post-accident operation.

The Conditions and Required Actions for this new support system LCO reflect the applicable attributes in TS 3.7.10, "Control Room Emergency Ventilation System (CREVS)," and TS 3.7.11, "Control Room Air Conditioning System (CRACS)," due to the similarity of those systems to the Class 1 E electrical equipment A/C trains. A discussion of the proposed Conditions and Required Actions follows:

Seourity Related Information

'Nithhold Under 1Q CFR 2.390 Attachment II to ET 17-0010 Page 3 of 48 Condition A of new TS 3.7.20 would be entered when one Class 1 E electrical equipment A/C train is inoperable. Required Action A.1 would require initiation of actions to implement mitigating actions with a specified Completion Time of immediately. Required Action A.2 would require verifying room area temperatures ::;; 90°F within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter.

An inoperable Class 1 E electrical equipment A/C train must be restored to OPERABLE status within 30 days per Required Action A.3. The 30 day Completion Time is bsised on the capability of the remaining OPERABLE Class 1 E electrical equipment A/C train to provide adequate area cooling for both trains of electrical equipment during normal and accident conditions (with mitigating actions implemented).

If the Required Action and associated Completion Time of Condition A of new TS 3.7.20 is not met, new Condition B requires a plant shutdown to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

New Condition C of TS 3. 7.20 would be entered when two Class 1 E electrical equipment A/C trains are inoperable. Required Action C.1 would require the immediate entry into LCO 3.0.3.

The Surveillance Requirements and associated Frequencies for this new support system LCO are similar to those of TS 3.7.11, "Control Room Air Conditioning System (CRAGS)," and with other TSs for systems that are started by an actuation signal, as follows:

SR 3.7.20.1 of new TS 3.7.20 would require that each Class 1E electrical equipment A/C train actuates on an actual or simulated actuation signal on an 18 month Frequency.

SR 3.7.20.2 of new TS 3.7.20 would require, that each Class 1 E electrical equipment A/C train be verified to have the capability to remove the assumed heat load on an 18 month Frequency.

The TS Table of Contents page iii is revised to reflect the incorporation of new TS 3.7.20.

2.2

System Description

The Class 1 E electrical equipment A/C trains provide a suitable environment for the Class 1 E electrical equipment. These A/C trains provide temperature control for the Engineered Safety Features (ESF) switchgear room components, DC switchboard room components, and 125 VDC battery room components.

Seo1:1rity Related Information V-'!ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 4of48 Figures 1and2 below provide a depiction of the Class 1 E Electrical Equipment A/C System. The specific rooms supplied by the Class 1 E electrical equipment A/C trains are:

SGK05A SGK05B SWBD RM N0.1 (3408)

SWBD RM NO. 4 (3404)

SWBD RM NO. 3 (3414)

SWBD RM NO. 2 (3410)

Battery RM NO. 1 (3407)

Battery RM NO. 4 (3405)

Battery RM NO. 3 (3413)

Battery RM NO. 2 (3411)

ESF SWGR RM NO. 1 (3301)

ESF SWGR RM NO. 2 (3302)

The Class 1 E electrical equipment A/C trains are independent trains that provide cooling of recirculated air in the rooms associated with that train. Each train consists of a prefilter, self-contained refrigeration system (using normal service water or ESW as a heat sink), centrifugal fans, instrumentation, and controls to provide for electrical equipment room temperature control.

The Class 1 E *electrical equipment A/C trains have emergency operation functions and also operate during normal plant operations. Each train is normally aligned to cool only the equipment associated with its emergency load group. The Class 1 E electrical equipment A/C trains are operated in a continuous recirculation mode to maintain the ESF switchgear room, the 125 VDC battery rooms, and the DC switchboard rooms to a temperature of :5 90°F as discussed in WCGS Updated Safety Analysis Report (USAR) Section 9.4.1.2.3 (page 9.4-12).

The design basis of the Class 1 E Electrical Equipment A/C System is to maintain temperature in the Class 1 E electrical equipment rooms to assure OPERABILITY of associated electrical equipment. The Class 1 E Electrical Equipment A/C System is designed so that the single failure of an active component coincident with a loss of offsite power will not impair the ability of the supported systems powered by the electrical equipment to fulfill their safety functions as discussed in USAR Section 9.4.1.1.1, Safety Design Basis Three.

During normal or emergency operations, each Class 1 E electrical equipment A/C train maintains the temperature in its associated electrical equipment rooms at a temperature of :5 90°F. The Class 1 E electrical equipment A/C trains are designed in accordance with Seismic Category I requirements.

The Class 1 E electrical equipment A/C trains are automatically started upon receipt of a Control Room Ventilation Isolation Signal (CRVIS), by the Loss-of-Coolant Accident (LOCA) sequencer and by the shutdown sequencer. A CRVIS is initiated by the control room ventilation radiation monitors, fuel building ventilation isolation signal, containment isolation phase A, containment atmosphere radiation monitors, containment purge exhaust radiation monitors, or manually. The ESW System is actuated upon receipt of a safety injection (SI) signal, a low suction pressure on the auxiliary feedwater pumps, or loss of offsite power.

Sesurity Related Information JJ'!ithhold Under 1 Q CFR 2.39Q Attachment II to ET 17-0010 Page 5of48

Security Related Information

'*".'ithhold Under 10 GFR 2.390 Attachment II to ET 17-0010

Page 6 of 48 2.3 Equipment Reliability A number of functional failures associated with the Class 1 E Electrical Equipment A/C System occurred in 2012, 2013, 2015, and 2016 (see Table 7 in Section 3.6). The failures have mainly involved contamination issues that have resulted in oil blockage or compressor damage. Actions taken as a result of the failures and subsequent evaluations have included trending to ensure adequate oil pressure, large scale parts replacement, and efforts to clean and monitor the cleanliness of the system.

Equipment reliability has been challenged due to the availability of replacement compressors and compressor parts. The compressor manufacturer that originally supplied the units for the skid no longer supports the nuclear industry. As a result, Wolf Creek Nuclear Operating Corporation (WCNOC) has pursued obtaining rebuilt compressors and reusing compressors previously removed following cleanup with limited success.

Near term actions have focused on increasing the reliability of the current system/configuration and limiting the impact a failure would have on the plant. The actions fall into two main categories; establishing and preparing compensatory measures to limit impact to the plant and performing maintenance and modifications to the existing cooling train skid to increase reliability.

The maintenance performed on the Class 1 E electrical equipment A/C trains during outages in addition to the normal preventive maintenance is focused on increasing the reliability of the units operating over a longer than normal frequency between preventive maintenance activities. In addition to this maintenance, replacement of the 'A' cooling train compressor with a new design was completed in Refueling Outage 21 (Fall 2016) and replacement of the 'B' cooling train compressor is scheduled for Refueling Outage 22 (Spring 2108).

Replacement of the compressors supports improving reliability and mitigating issues with parts availability. The 'A' cooling train compressor was replaced first since it has both operated.in a prolonged degraded condition and experienced numerous previous failures.

2.4 Need for Change The Class 1 E electrical equipment A/C trains have emergency operation functions and also operate during normal plant operations. Each train is normally aligned to cool only the equipment associated with its emergency load group. The Class 1 E electrical equipment A/C trains are operated in a continuous recirculation mode to maintain the ESF switchgear room, the 125 VDC battery rooms, and the DC switchboard rooms to a temperature of::; 90°F as discussed in USAR Section 9.4.1.2.3 (page 9.4-12). There is not an independent/redundant A/C train for each cooling train that would allow taking a cooling train out of service for planned maintenance or that would provide backup cooling due to a failure.

The WCGS TSs (Reference 6.1) were submitted for Nuclear Regulatory Commission (NRC) review on August 5, 1982 in conjunction with the submittal of the Callaway Plant Technical Specifications (Reference 6.2) on February 29, 1982. The proposed TSs were based on NUREG-0452, Rev. 4, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors."

NUREG-0452, Rev. 4, did not include a specification associated to the cooling system for the Class 1 E electrical equipment. The WCGS Facility Operating License NPF-42 (Reference 6.3),

Security Related Information lJ.'!ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 7of48 together with the Technical Specifications and the Environmental Protection Plan were issued on June 4, 1985. As such, the WCGS proposed and issued TSs did not include a specification associated to the cooling system for the Class 1 E electrical equipment.

In October of 1995, WCNOC joined with Pacific Gas and Electric (Diablo Canyon Power Plant),

TU Electric (Comanche Peak Steam Electric Station), and Union Electric (Callaway Plant) in a joint effort to convert the current TSs (CTS) to the improved TSs (ITS). This conversion process was based, in part, on the understanding reached with the NRC that each plant may maintain its licensing basis as established by the CTS and may optimize their ITS based on a member's CTS in order to maximize commonality. The conversion from CTS to ITS was based on NUREG-1431, Rev. 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995. During the development of the license amendment request (LAR), NRC Administrative Letter 96-04, "Efficient Adoption of Improved Standard Technical Specifications," was issued and stated, in part:

The major objective of converting from plant-specific technical specifications to the improved STS is to achieve as much consistency in the license requirements as possible, to the extent that the plant-specific design basis can conform with the related typical plant design reflected in the improved STS. To ensure efficient and timely staff review of conversions to the improved STS, the associated license amendment applications must cle.arly identify in the forwarding letter those changes to the technical specifications that are not directly related to the conversion amendment. These "beyond scope" issues, which are generally characterized as changes that differ from both the existing technical specifications and the improved STS, tend to unnecessarily complicate and delay the conversion review process.

The development of the ITS was primarily focused on maintaining the licensing basis as established by the CTS and achieving commonality with NUREG-1431, Rev. 1. NUREG.,.1431, Rev. 1, or the other three licensees CTS did not include a specification associated to the cooling system for the Class 1 E electrical equipment. Amendment No. 123 (Reference 6.4) approved the conversion to ITS and was implemented in December 1999.

In August 2000, Revision 5 to the Technical Requirements Manual (TRM) incorporated new Technical Requirement (TR) 3.7.23, "Class 1E Electrical Equipment Air-Conditioning (A/C)." With one Class 1 E electrical equipment A/C train nonfunctional with the plant in MODES 1 through 4, TR 3.7.23 allowed up to a 7-day delay period before declaring the supported Class 1 E electrical equipment inoperable (in the area served by the A/C train) and entering the applicable Conditions and Required Actions of TS 3.8.4, TS 3.8.7, and TS 3.8.9.

TR 3.7.23 contained the following requirements:

Mitigating actions (opening doors and de-energizing 480/120 V instrument transformers),

verification of area temperatures, and a 7-day Completion Time if one Class 1 E electrical equipment A/C train was nonfunctional.

Declare affected equipment inoperable/nonfunctional if both Class 1 E electrical equipment A/C trains are nonfunctional.

Seourity Related Information

'.lithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 8 of 48 A Technical Surveillance Requirement to verify the capability to remove the assumed heat load once per 18 months.

In September 2010, three issues were identified regarding the requirements specified in TR 3.7.23 when one of the two Class 1E electrical equipment A/C trains is nonfunctional. The requirements specified in TR 3.7.23 were deemed to be adequate pending additional analysis.

The three issues involved are discussed in detail below:

TS Section 1.1 -

OPERABILITY definition requirements imposed on non-TS support systems Application of LCO 3.0.6 and the Safety Function Determination Program Temporary waiver of the single failure criterion while operating under a TS Condition OPERABILITY Definition The Class 1 E electrical equipment A/C trains are a support system for supported equipment covered by individual TS LCOs.

Therefore, the OPERABILITY of the supported electrical equipment is directly tied to the functionality of the support system, i.e., the Class 1 E electrical equipment A/C trains, based on the TS 1.1 definition of OPERABILITY which states:

"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)."

That definition ties support system functionality to supported system OPERABILITY, except as provided per TS LCO 3.0.6. The issue to be resolved by this amendment application concerns a non-TS support system that supports several electrical systems which have specific LCOs in the TSs.

In most support system-to-supported system associations (with each system typically having two redundant subsystems or trains), the 'A' train support subsystem is associated only with the 'A' train supported system, and the 'B' train support system is associated only with the

'B' train supported system.

In the case of the Class 1 E electrical equipment A/C trains the situation is not as straightforward.

If mitigating actions are taken, such as opening the doors between rooms housing separate electrical equipment trains and de-energizing two plant instrumentation transformers, a plant specific calculation determined that one Class 1 E electrical equipment A/C train can support both trains of Class 1 E electrical equipment for normal operation and for accident conditions.

Therefore, in this case, a non-TS support subsystem may have a nonfunctional train (i.e., one nonfunctional Class 1 E electrical equipment A/C train), yet neither supported electrical equipment train is deprived of adequate cooling, assuming no additional single failure. (See Single Failure Criterion discussion below.)

Security Related Information

\\"!ithhold Under 1 Q CFR 2.390 Attachment II to ET 17-0010 Page 9 of 48 When the plant is operating in MODES 1 through 4, the applicable TS LCOs for the supported systems (TS 3.8.4 and TS 3.8.9) contain Conditions and Required Actions with very short Completion Times. Required Action A.1 of TS 3.8.4 and Required Action C.1 of TS 3.8.9 have 2-hour Completion Times for one inoperable DC electrical power subsystem and one inoperable DC electrical power distribution subsystem, respectively. Each DC electrical power subsystem, or train, contains two 125 VDC buses with each bus energized from its battery and a battery charger or spare charger. Each DC electrical power distribution subsystem, or train, contains two 125 VDC buses with each bus energized to the proper voltage from either its battery or a battery charger. Required Action A.1 of TS 3.8.9 has an 8-hour Completion Time for one inoperable AC power electrical distribution subsystem with each subsystem, or train, consisting of one 4.16 kV bus and two 480 VAC load centers as listed in TS Bases Table B 3.8.9..:1. Required Action B.1 of TS 3.8.9 has a 2-hour Completion Time for one inoperable AC vital bus subsystem with each subsystem, or train, consisting of two 120 VAC AC vital buses as listed in TS Bases Table B 3.8.9-

1.

Of more pressing concern from a plant shutdown perspective is the fact that the Conditions and Required Actions of TS 3.8.7 only address having one inverter inoperable ratherthan one inverter subsystem or train. Since one nonfunctional Class 1 E electrical equipment A/C train renders the supported train of affected electrical equipment inoperable (i.e., two inverters among other affected equipment), LCO 3.0.3 would be required to be entered since there is not a Condition for two inoperable inverters in TS 3.8. 7. LCO 3.0.3 requires action to be taken within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the plant in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , in MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and in MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Therefore, absent a support system TS LCO to declare not met, the control room staff declares the affected electrical equipment inoperable and their LCOs not met and enters LCO 3.0.3 when a Class 1 E electrical equipment A/C train is discovered to be nonfunctional.

TS LCO 3.0.6 The provisions of TS LCO 3.0.6 allow the following relaxation, sometimes referred to as an allowance to not "cascade:"

When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Seourity Related Information

\\t'.'ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 10 of 48 Explicit within this allowance is the understanding that the support system is covered by its own LCO within the TSs (i.e., non-TS support systems are not governed by LCOs). That is not currently the case for the Class 1 E electrical equipment A/C trains. Adding new TS 3. 7.20 for the support system function performed by the Class 1 E electrical equipment A/C trains allows LCO 3.0.6 to be applied such that support system inoperability is dealt within the Conditions and Required Actions of TS 3.7.20.

Single Failure Criterion Previous NRC guidance regarding the temporary relaxation of the single failure criterion when a TS LCO is not met (NRC Generic Letter 80-30) indicated that these temporary relaxations apply only when operating pursuant to a Condition and associated Required Action(s) of the TSs, not when applying a compensatory action specified in the TRM (compensatory measures are currently specified in plant procedures) which is not within the scope of the TSs.

During the week of May 23, 2012, a NRC Problem Identification and Resolution team inspection (results are documented in Reference 6.5) identified several concerns with the incorporation of calculation GK-06-W, Revision 2, "SGK05A/B Class 1 E Electrical Equipment Rooms A/C Units, Single Unit Operation Capability," into plant documents. One of the concerns related to the calculation requirements for the use of temporary ventilation fans and the fans not being powered from a safety related source. On May 29, 2012, the 'B' cooling train was declared nonfunctional due to the oil pump pressure degrading. The 'B' cooling train unit was restored to functional status prior to completing a prompt OPERABILITY determination. On June 4, 2012, the compressor for

'A' cooling unit was found tripped on low oil pressure and the cooling unit declared nonfunctional.

During the Operability Determination and Functionality Assessment process it was determined that OPERABILITY of the associated train Class 1 E electrical equipment could not be maintained without additional compensatory measures and for a limited period of time.

Subsequently, WCNOC revised TRM TR 3.7.23, "Class 1 E Electrical Equipment Air-Conditioning (A/C)," to immediately require entry into the applicable Section 3.8 Specifications for a nonfunctional Class 1 E electrical equipment A/C train and use of procedure SYS GK-200, "Inoperable Class 1 E A/C Unit," was suspended.

On November 9, 2012, the NRC issued Integrated Inspection Report 05000482/2012004 (Reference 6.6) that included Unresolved Item 2012004-01, "Determine Licensing Basis and Capability of One Vital Air Conditioning Unit to Cool Both Trains of Class 1 E Electrical Equipment."

The unresolved item identified five specific issues, which two of the issues are provided below:

(1)

Wolf Creek relied on compensatory measures to open all doors between trains of batteries and switchgear, posting continuous fire watches, and using non-safety powered box fans to blow air between rooms. The inspectors questioned the reliability and cooling capability of these measures, which were used as a basis for assuring the operability of safety-related systems. Specifically:

a. the temporary equipment that did not have a safety-related power source with a diesel generator backup

b. the temporary air flow paths did not appear to ensure adequate air flow between trains

Seourity Related Information

\\".'ithhald Under 10 CFR 2.390 1 to ET 17-0010.

Page 11of48

c. portions of the temporary air flow path went through a corridor that was not cooled, allowing unaccounted-for heat as well as loss of cooled air, since there was no way to efficiently move all the cooled air to the other trains' room

d. the heat loads and cooling capacity were not adequately accounted for (see below)

(2)

The licensee's creation of TRM 3.7.23 appeared to conflict with existing technical specifications that covered the situation. Specifically, cooling was required to support the. safety functions of the associated batteries, inverters and switchgear. The definition of "operable" in technical specifications stated that for a system to be considered operable, all necessary cooling systems must also be capable of performing their related support functions. Part 9900 guidance for assessing operability further states that, in order to be considered operable, an SSC must be capable of performing the safety functions specified by its design within the range of specified physical conditions, which would include room temperature. Creating a TRM LCO allowing the support system to be out of service would not alleviate the need to consider the impact to the operability of the supported systems.

A design basis reconstitution was performed for the Class 1 E Electrical Equipment A/C System.

Calculation GK-06-W was revised to address the issues in the unresolved item and incorporated other enhancements. In October 2013, TR 3.7.23 was deleted from the TRM. These activities and plant modifications in late 2013 resulted in the use of the OPERABILITY determination process and the allowance of compensatory measures (including providing safety related power for the temporary fans and providing a means to seismically restrain the fans) such that one Class 1 E electrical equipment A/C train can provide adequate area cooling for both trains of electrical equipment during normal and accident contlitions.

Additionally, WCNOC suspended the performance of on-line preventative maintenance activities when it was determined that implementation of compensatory measures on a non-TS support system may not be consistent with the guidance in NRC Inspection Manual Chapter (IMC) 0326, "Operability Determinations &

Functionality Assessments for Conditions Adverse to Quality or Safety."

Currently, the functionality requirements imposed on the Class 1 E electrical equipment A/C trains at WCGS are governed by procedures AP 26C-004, "Operability Determination and Functionality Assessment," and SYS GK-200, "Non-Functional Class 1 E A/C Unit." In the event of a degraded or nonconforming Class 1 E electrical equipment A/C train that results in declaring the train nonfunctional when the plant is in MODES 1 through 4, procedure AP 26C-004 requires declaring the supported pass 1 E electrical equipment inoperable (in the area served by the nonfunctional A/C train) and entering the applicable Conditions and Required Actions of TS 3.8.4, TS 3.8.7, TS 3.8.9, and LCO 3.0.3. Compensatory measures are established per the guidance in procedure SYS GK-200 to restore the Class 1 E electrical equipment to an OPERABLE but degraded status.

The compensatory measures include opening affected area room doors, establishing fire watches, installing seismic temporary fans powered from a safety related source, increased monitoring of room temperatures, and monitoring specified load center transformer amps. The establishment of compensatory' measures is consistent with the guidance in NRC IMC 0326.

Further, procedure AP 26C-004 specifies restoring the Class 1 E electrical equipment A/C train in a time frame commensurate with the safety significance not to exceed 7 days.

Seourity Related Information

'*"lithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 12 of 48 The failure of a Class 1 E electrical equipment A/C train can be identified in various ways.

Procedure CKL ZL-004, "Turbine Building Reading Sheets," requires a building watch to monitor/log various cooling train parameters twice a day (once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months shift). Parameters monitored include (not all inclusive) if the cooling unit is in operation, compressor oil pressure, compressor suction pressure, compressor oil differential pressure, compressor discharge pressure, filter differential pressure, AC amps, freon level, and oil level.

Additionally, this procedure logs the temperatures in the 125 voe battery rooms twice a day (once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months shift). Building watch attentiveness to changing conditions can result in the identification of increasing temperatures in the equipment rooms. Technical Surveillance Requirement (TSR)

3. 7.22.1 verifies the required area temperatures are within limits with a specified Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Procedure STS CR-001, "Shift Log for MODES 1, 2 & 3," and STS CR-002, "Shift Log for MODES 4, 5, and 6," satisfies the monitoring requirements of TSR 3.7.22.1 by verifying the area room temperatures every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Computer points GKD0091, GKD0092, GKD0093, GKD0094, GKD0130 and GKD0137 are used to verify the DC switchboard rooms and ESF switchgear room temperatures are less than 87°F (actual room temperatures are not recorded) and provide an alarm on the main control board. A review of the computer points for the previous three years identified only one instance of a switchgear room exceeding 87°F. This occurred during a refueling outage when a temporary cooling unit was being used due to outage plant conditions.

The temporary cooling ductwork was adjusted and the room temperature returned to a desired value within one hour of discovery. There are no computer points for the 125 VDC battery rooms.

The temperatures in these rooms are manually verified once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months with a thermometer installed in the rooms (the DC switchboard rooms and ESF switchgear rooms also have thermometers) by procedures STS CR-001 and STS CR-002. Additionally, CKL ZL-004 provides for monitoring the battery room temperatures twice a day. However, the heat loads in the battery rooms are much lower than the other electrical equipment rooms, so it is expected that the other rooms will reach the alarm temperature faster than the battery rooms.

On August 15, 2016, the 'B' cooling train was declared nonfunctional due to a drain line backup condition discovered by the building watch. The applicable Conditions and Required Actions of TS 3.8.4, TS 3.8.7, TS 3.8.9 were entered and LCO 3.0.3 was entered when the supported electrical equipment was declared inoperable. Compensatory measures were established per the guidance in procedure SYS GK-200 to restore the Class 1 E electrical equipment to an OPERABLE but degraded status. Table 1 below shows the room temperatures that resulted with the current compensatory measures implemented.

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'.".Vithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 13 of 48 Table 1 TRAINA TRAIN B TIME 3301 3408 3414 3407 3413 3302 3410 3404 3411 3405 OUTSIDE TEMP 8/15/16 0500 0520(1) 0600 1100 1110(1) 1200 1700 1701(1) 1800 2200 2240(1) 2300 8/16/16 0400 0410(1) 0500 1000 1005(1) 1100 1115(1) 1200(1) 1200 67.5 73 72 71 71.5 73 74.5 74.5 75.5 73 72.5 66.08 73.19 73 73 71.5 73 73 76 75 79.5 73.5 73.5 74.61 77.76 73 73.5 71.5 73.5 73.5 76.5 75.5 81(2) 74 74.5 78.66 72.65 73 74 71.5 74 73.5 77 76 79 74.5 75.5 70.41 69.36 72.5 73.5 72 72.5 73.5 70 75 75 73.5 74 68.99 73.57 73 74 72 73.5 74 76 76 78 74 75 76.26 73 74 72.5 73 74 71.5 75 76 74 75 72.5 73 71 72.5 73 69 73.5 73.5 73.5 75 79.4 (1lTemperature taken locally with a calibrated thermometer and documented in STS CR-004, "Shift Log for Additional Monitoring."

(2lThermometer for room temperature was moved to a different location (was behind opened door) to obtain a more representative room temperature.

3301 (GKD0137) - ESF SWGR RM NO. 1 3408 (GKD0091) - SWBD RM NO. 1 3414 (GKD0092)- SWBD RM NO. 3 3407 - Battery RM NO. 1 3413 - Battery RM NO. 3 3302 (GKD0130) - ESF SWGR RM NO. 2 3410 (GKD0094) - SWBD RM NO. 2 3404 (GKD0093) - SWBD RM NO. 4 3411 - Battery RM NO. 2 3405 - Battery RM NO. 4 The proposed TS 3.7.20 would allow LCO 3.0.6 to be applied such that support system inoperability is dealt within the Conditions and Required Actions of TS 3.7.20 (as long as safety function has not been lost). The planned modifications (discussed in Section 3.5 below) would allow one Class 1 E electrical equipment A/C train to provide adequate area cooling for both trains of Class 1 E electrical equipment during normal and accident conditions while minimizing mitigating actions.

3.0 TECHNICAL EVALUATION

The proposed TSs in conjunction with planned modifications will minimize challenges to plant systems and the plant operators, facilitate maintenance activities, as well as enhancing plant safety.

This section summarizes the evaluations that support the proposed change.

The justification for this amendment includes a calculation of limiting temperatures reached in the effected electrical equipment rooms with one Class 1 E electrical equipment A/C train out of

Sesurity Related Information

'Nithhold Under 1Q CFR 2.39Q 1 to ET 17-0010 Page 14 of 48 service. The calculation assumes the implementation of plant modifications that are discussed in Section 3.5 below.

3.1 Normal and Design Basis Accident Environmental Conditions The Class 1 E electrical equipment A/C trains are operated in a continuous recirculation mode to maintain the ESF switchgear room, the 125 VDC battery rooms, and the switchboard rooms to a temperature of~ 90°F as discussed in USAR Section 9.4.1.2.3.

USAR Section 3.11 (B), "Environmental Design of Mechanical and Electrical Equipment," provides information on the environmental conditions and design bases for which the mechanical, instrumentation, and electrical portions of the engineered safety features, the reactor protections systems, and other safety related systems are designed to ensure acceptable performance during normal and design basis accident environmental conditions. Normal operating environmental conditions are defined as conditions existing during routine plant operations.

These environmental conditions, as listed in USAR Table 3.11(B)-1, represent the normal maximum and minimum conditions expected during routine plant operations. Accident environmental conditions are defined as those deviating from the normal operating environmental conditions.

These conditions are specified in USAR Table 3.11 (B)-2.

Revision 28 of the USAR placed the information in these tables in the Equipment Qualification Design Basis Document (EQSD-1) and is considered incorporated by reference. The normal operating environmental conditions for the Class 1 E electrical equipment rooms and accident environmental conditions are provided in Table

2.

Table 2 Room No.

Area Pressure Temp.

Relative Normal Rad-60yr Rad-6 (Normal (Normal and Humidity Dose (Normal)

Months and Accident)

Rate (Accident)

Accident)

(R/hr) 3301 ESF switchgear room Atmospheric 90 70

<0.0005 262 rads 2.5 rads Note 7 3302 ESF switchgear room Atmospheric 90 70

<0.0005 262 rads 2.5 rads Note 7 3404 Switchboard room (No. 4)

Atmospheric 90 70

<0.0005 262 rads 0.0005 rads Note 7 3405 Battery room Atmospheric 90 70

<0.0005 262 rads 2.5 rads Note 7 3407 Battery room Atmospheric 90 70

<0.0005 262 rads 2.5 rads Note 7 3408 Switchboard room (No. 1)

Atmospheric 90 70

<0.0005 262 rads 0.0005 rads Note 7 3410 Switchboard room (No. 2)

Atmospheric 90 70

<0.0005 262 rads 0.0005 rads Note 7 3411 Battery room Atmospheric 90 70

<0.0005 262 rads 2.5 rads Note 7 3413 Battery room Atmospheric 90 70

<0.0005 262 rads 2.5 rads Note 7 3414 Switchboard room (No. 3)

Atmospheric 90 70

<0.0005 262 rads 0.0005 rads Note 7 Note 7)

The rooms m the control building referenced to this note have ESF coolers which maintain the temperature and relative humidity at or below 90°F and 70 percent, respectively, for all conditions except during loss of offsite power or a single nonfunctioning SGK05A or SGK05B unit concurrent with accident

Security Related Information

'.'Vithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 15 of 48 condition (LOCA) heat loading. During a loss of offsite power, when Class 1 E equipment is powered by the emergency diesels, Class 1 E room temperatures may reach 92°F, due to the possibility of the fan running slower because of variation in the diesel generator frequency/voltage. With a single nonfunctional SGKOSA or SGKOSB unit concurrent with accident condition (LOCA) heat loading as well as maximum outdoor ambient temperature, the room temperature in the rooms may increase to a maximum of 104°F.

During the initial licensing of WCGS, a review of equipment environmental qualification programs was performed to the positions in NUREG-0588, "Interim Staff Position on Environmental Qualification of Safety-Related Equipment." The Class 1 E electrical equipment was specified to mild environment conditions thus was exempted from the NUREG-0588 review program. USAR Section 3.11 (B).2.3.2, "Class 1 E Electrical Equipment Rooms," states, The air-conditioning systems installed for these areas are designed to maintain the room temperature at or below 90°F under all operating conditions when the outdoor air is at summer design conditions.

All safety-related equipment in the Class 1 E electrical equipment ro.oms is designed to sustain the specified environment conditions. Documentation of tests and/or analyses confirm that this equipment operates satisfactorily under the specified environmental conditions.

TRM TR 3.7.22, "Area Temperature Monitoring," provides requirements associated to allowable temperature limits in the vicinity of major equipment. This TR establishes temperature limits during normal operation for specific locations in various buildings. The temperature limits are related to the expected thermal-life for the hardware, which operates in the areas where the temperatures are monitored and controlled. The temperature limits established for the Class 1 E electrical equipment rooms is ::;; 90°F (the temperature limits include an allowance for instrument error of +/-3°F) with an alarm setpoint of 87°F.

The normal operating temperature of the Class 1 E electrical equipment rooms, as specified in the USAR, remains. 90°F maximum, as normally the temperatures in the Class 1 E electrical equipment rooms are maintained between 68°F and 75°F and during normal equipment operation (both SGK05A or SGK05B trains in service) the room temperatures are assured to remain below 90°F. A single functional (OPERABLE with the implementation of new TS 3.7.20) Class 1 E electrical equipment A/C train providing area cooling for both electrical equipment trains concurrent with accident condition (LOCA) heat loading will maintain the equipment room temperatures less than the 104 °F maximum accident/faulted environmental conditions.

3.2 Single Cooling Train Operation Calculation Calculation GK-M-016, Revision 1, "Wolf Creek Control Building Loss of Class 1 E A/C GOTHIC Room Heat Up Analysis With Installed Crosstie Fans and Louvers," evaluates the capability of one train of the Class 1 E Electrical Equipment A/C System to supply adequate cooling for both trains of the Class 1 E electrical equipment.

Seourity Related Information

'.&Jithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 16 of 48 3.2.1 Methodology A GOTHIC model was developed for WCNOC by Numerical Applications (NAI). GOTHIC Version 8.0(QA) thermal-hydraulic analysis software package is used to develop the WCGS Control Building model developed in Calculation GK-M-016. GOTHIC is an integrated, general purpose thermal-hydraulics software package for design, licensing, safety and operating analysis of nuclear power plant containments and other confinement build.ings. GOTHIC Version 8.0(QA) has been qualified under the NAI Quality Plan that complies with 10 CFR 50, Appendix B. A review of GOTHIC error notifications for Version 8.0(QA) was performed. Known GOTHIC errors for version 8.0 and earlier have been reviewed and dispositioned for this analysis and the associated model.

The GOTHIC model uses a subdivided volume approach for modeling rooms in the Control Building 2000', 2016', 2032' and 2073.5' levels (Control Building). The GOTHIC model includes a large portion of the Control Building, with the most detail in the model applying to the 2000' and 2016' levels of the Control Building. The Class 1 E Electrical Equipment NC System is explicitly detailed in the model. Other ancillary systems, such as the Normal Control Building Air Supply (SGK02), Normal Control Building Exhaust (CGK01NB) and 2032' level (lower cable spreading room) and 2073.5' level (upper cable spreading room) are modeled to the extent necessary to give a reasonable approximation of the interaction to the Class 1 E electrical equipment rooms.

The lower and upper cable spreading rooms are modeled due to the interaction of the Control Building Pressurization System with the 2000', 2016', 2032', and 2073.5' levels, as well as the interaction with the non-safety normal Control Building Heating Ventilation and Air-Conditioning (HVAC) Systems.

3.2.1.1 Control Volumes (Rooms and Ductwork)

The first step in the input development is to develop the list of rooms to be modeled, along with the definition of the type of modeling to be applied. The room list for the Control Building was developed primarily from the general arrangement drawings, with modifications to adjust for rooms/HVAC duct that needed to be divided into 2 or more parts, and rooms/HVAC duct that should be combined. Each room/area of the Control Building is modeled with separate nodes in the GOTHIC model so that environmental profiles for the desired areas can be developed. In general, the 2000', 2016', 2032' and 2073.5' elevations of the Control Building are modeled with subdivided volumes.

3.2.1.2 Flow Paths (Doorways, Transfer Grills, Ductwork Registers, and other Hydraulic Connections)

Flow paths are used to represent the physical connections associated with the detailed rooms and ductwork.

These connections include doors, hatches, drains, and various ductworks.

Physical dimensions of openings and doorways are provided. Door components are modeled on the flow paths that represent solid doors. Doors may be opened or closed as needed depending on the scenario under consideration. Transfer grills have valve components on the flow paths, though not active, that can model the closure of the transfer grills by activation of the fusible links located within the transfer grills. The HVAC cooling coils have valves associated with the drain lines that were added to ensure the buildup of condensation within the cooling coil control volume does not affect the model results and run time.

Seourity Related Information

'A(ithhold Under 10 GFR 2.390 Attachment II to ET 17-0010 Page 1.7 of 48 In order to allow natural circulation, or buoyancy-driven flow, between volumes each of the doorways and shared volume boundary openings is divided into an upper and lower half with each having a portion of the total flow area. For this calculation, only the doors associated with the Class 1 E electrical equipment are modeled. Flqw paths that represent any connection other than room to room connections, such as connections to boundary conditions, HVAC ductwork, and registers, are also developed in this calculation. Similar to the inertia length for the doors and transfer grills, the inertia length for the ductwork and registers is generally set to approximate distance from room center to duct center.

3.2.1.3 Heat Sink Conductors (Walls, Floors, and Ceilings)

Walls, floors and ceilings are modeled as thermal conductors to provide appropriate heat transfer between the areas of interest. Conductors are included for walls, floors and ceilings of the detailed rooms and vertical volumes. Some metal surfaces, such as certain metal equipment, are also modeled as conductors. GOTHIC computes the convective heat transfer coefficients depending on the orientation, type and configuration of thermal conductors based on the assigned surface option. Surface options are interchangeably referred to as Heat Transfer Coefficient (HTCs) types based on terminology used in earlier versions of GOTHIC. Certain surface options are user-specified, but in such cases are deterrnined by calculations external to the GOTHIC model and such calculations are documented in this analysis.

Note that when a door is modeled, with flow paths and door components, the surface area occupied by the door is not included in the wall conductor surface area for which the door resides.

For doors that are not modeled in the Control Building, the surface area occupied by the door is included within the surface area of the wall in which the door resides. Although this additional surface area would have negligible effect on model results, it is included for completeness. The surface area for the walls that include doors that are not modeled is calculated for both with and without the surface area of the door included in the wall surface area. There are no wire mesh doors in the Control Building, but if there were, then including the surface area of the door within the wall conductors would not be appropriate.

The initial temperature of conductors representing heat sinks is set close to the room initial temperatures.

After stabilizing the room pressures, the conductor temperature profiles are initialized as if the adjoining room temperatures had existed for an infinite period of time, in other words, the model is in equilibrium.

3.2.1.4 Heat Loads Heat loads are added to the model using heated conductors. Heated conductors are used to allow spanning the heat loads across multiple cells. Most equipment is located in the lower elevations of each room therefore the equipment heat conductors are found in the lower half cells for the rooms. Most lights and cable trays are found in the upper region of the rooms, therefore the lighting and cable trays heat conductors, if any is specified, is located in the upper half cells for the rooms.

If a room is modeled, and set to a constant temperature, then the heated conductors are spanned throughout the room with a large surface area.

Seourity Related Information

'*".'ithhold Under 1 g CFR 2.390 Attachment II to ET 17-0010 Page 18 of 48 The methodology used for conductors representing heat loads is to apply a fixed heat flux. The -

flux is applied using a Specified Heat Flux type HTC on one side. Given the common fixed heat flux, the surface area of each conductor is calculated by simply dividing the heat load by the fixed heat flux. An HTC type. with a large convective heat transfer coefficient is applied to the opposite side of the conductor to ensure that all of the heat is applied to the room with minimal thermal lag.

The methodology used for conductors representing rooms that are modeled having a constant temperature is to use a Specified Temperature type HTC on one side, which is set to the constant room temperature. Then a HTC type with a large convection heat transfer coefficient is applied to the opposite side of the conductor. To ensure that the room temperature stays at the specified constant temperature the conductor surface area is set to a high value, typically 1 x 106 ft2.

3.2.1.5 Components Components are used to model the operation of specialized equipment, dampers, fans, coolers, heaters, doors, etc. that may be located within a control volume or on a flow path or 30 connector.

These components may be turned on and off, or opened and closed, by input referred to as trips.

Trips are actuated by time or by calculated parameters such as a volume temperature or liquid level.

3.2.1.6 Boundary Conditions Boundary conditions model fluid mass and energy sources, such as atmospheric pressure. The boundary conditions connect to control volumes via flow paths. Initial fluid conditions specified for each boundary condition includes temperature, humidity, gas composition and pressure.

3.2.1. 7 Outdoor Air Temperature and Sol-Air The outdoor air temperature is modeled using a function simulating the daily temperature cycle (diurnal cycle) for a typical day with the peak temperature at a specified maximum temperature.

The methodology used to develop the temperature function is based on the American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE) Handbook methodology and the daily temperature range for Topeka Forbes Field, KS, USA. The Sol-Air temperature on the roof and outside walls is developed from the ASH RAE Handbook.

3.2.1.8 Resources - Materials, Functions, and Trips GOTHIC resources are parameters that are used by other elements and are defined in the model as needed. Resources include functions, control variables, trips and materials.

3.2.1.9 Run Parameters and Miscellaneous Inputs Transient run parameters are specified (time step size, edit interval, graphics edit interval, etc.).

When all required features of the model have been defined, the input file can be written and GOTHIC Solver started to run the transient. The model is run for thirty days (720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months ).

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'J'lithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 19 of 48 3.2.1.10 Flow Networks A flow network is developed to represent abridged versions of the normal Control Building HVAC systems. The flow network is made up of a supply and an exhaust fan, links representing segments of ductwork and nodes representing rooms/areas or duct junctions.

3.2.2 Inputs/Assumptions Calculation GK-M-016 details the ability of a single Class 1 E electrical equipment A/C train to maintain the Class 1 E equipment rooms below the maximum design temperature of 104°F. In order to provide this cooling capability, recirculation fans must be actuated to circulate the cool air from the operating cooling train to the rooms of the out-of-service cooling train and return the heated air to be cycled through the train to be cooled.

Case 1 of the calculation evaluates the SGK05A train out-of-service, under normal operating I

conditions and Case 2 evaluates the SGK05B train out-of-service, under normal operating conditions. Case 3 of the calculation evaluates the SGK05A train out-of-service, under post-LOCA operating conditions and Case 4 evaluates the SGK05B train out-of-service, under post-LOCA operating conditions. Post-LOCA operating conditions were chosen for Cases 3 and 4 as this provides the worst-case heat loading for the Class 1 E electrical equipment rooms. A Design Basis Accident (OBA) does not have any direct effects on the Class 1 E electrical equipment rooms in terms of heat added to the Control Building from hot water piping, or radiation environment.

The heat loading into the rooms is a result of electrical heat loads in the transformers, cables and circuit breakers due to the equipment that is in operation.

The primary inputs and assumptions that are utilized in the GOTHIC model are shown in the Table 3below.

A 95°F temperature is utilized as the initial condition starting Class 1 E electrical equipment room temperature for the post-LOCA cases. The proposed Technical Specification Required Action A.2 requires verifying room area temperatures are s; 90°F. The 90°F is the normal operation maximum temperature identified in the USAR for the Class 1 E electrical equipment rooms.

WC NOC has elected to use an initial condition temperature of 95°F based on the normal operation cases of the GOTHIC model. The normal operation cases show that some rooms could see an average room temperature of 95°F with a single SGK05A/B train operating and maximum heat loading conditions. This elevated temperature for the post-LOCA model cases is utilized to provide additional conservatism and margin in the calculation.

For the GOTHIC model post-LOCA cases, a start time at time= 0 seconds (T=O) is assumed for the starting of the recirculation fans. This assumption is based on an operational philosophy that if the recirculation fans were in service at the initiation of a LOCA they would remain in service for the event and if a SGK05 train were to fail after the initiation of a LOCA event shutdown of the plant would continue on the OPERABLE train of Class 1 E electrical equipment and the recirculation fans would not be placed in service for the failed cooling train. It is noted that in many safety analysis calculations, a loss of offsite power (LOOP) is assumed to occur. USAR Section 15.6.5.3.2 specifically states that "for the small break LOCA (SBLOCA), LOOP is assumed, which results in the limiting single failure assumption of the loss of one diesel generator (DG) and a subsequent loss of one train of pumped Emergency Core Cooling System (ECCS)."

Seourity RelateEt Information

\\&JithholEt UnEter 10 CFR 2.390 1 to ET 17-0010 Page 20 of 48 This same assumption is not applied to the large break LOCA in this section. As noted in this section, assumption of the LOOP generally leads to the single failure of a train of DG/ECCS/Class 1 E electrical equipment, and is not required to be postulated for every design event. The GOTHIC calculation GK-M-016 evaluates a plant design condition, and is not an accident analysis evaluation.

Additionally, USAR Section 7.3 states "A power interruption to the ESFS, in conjunction with a LOCA or other postulated accident, is believed to be a highly improbable event.

However, the accident analyses for WCGS assume a loss of offsite power coincident with certain postulated events, such as a LOCA. In addition, it is assumed that a single failure occurs which causes the loss of one of the two onsite emergency diesel generators." Thus, while a LOOP coincident with a LOCA is possible, it is highly improbable, and is not required to be postulated for design analysis. USAR Section 6.3.2.1 states "The ECCS components are designed so that a minimum of three accumulators, one centrifugal charging pump, one safety injection pump, and one residual heat removal pump, together with their associated valves and piping, ensure adequate core cooling in the event of a design basis LOCA or provide boration in the event of a steam/or feedwater break accident. The redundant onsite emergency diesels assure adequate emergency power to at least one train of electrically operated components in the event that a loss of offsite power occurs simultaneously with a LOCA." Therefore, one train of Class 1 E electrical equipment is adequate to ensure safe shutdown of the plant.

Table 3 - Base GOTHIC Inputs/Assumptions lnput/Assumotion Normal Operation Case Post-LOCA Operation Case Heat loading conditions Normal Operation from Post-LOCA Operation from Calculation GK-E-001 Rev. 04 Calculation GK-E-001 Rev. 04 Fan size I Fan start time 5000 CFM (nominal) I T=3600 5000 CFM (nominal) I T=O secs.

secs.

Initial temperature of rooms 72°F 95°F Surrounding room Generally 104°F unless other Generally 104°F unless other temperatures (equipment calculations have a more calculations have a more specific rooms, duct/cable chases) specific value value Outdoor design temperature 97°F 97°F Control Building Off Both trains on for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , then Pressurization System one train off Non-Safety HVAC units Operating at 75% of design flow, limited modeling in Off GOTHIC Minimum air flow rates (CFM)

Room 3301 7850 7850 Room 3407 220 220 Room 3408 1090 1090 Room 3413 270 270 Room 3414 860 860 Room 3302 8430 8430 Room 3404 1060 1060 Room 3405 220 220 Room 3410 860 860 Room 3411 200 200

Security RelateEI Information

'J'JithholEI UnEler 1Q CFR 2.39Q Attachment II to ET 17-0010 Page 21 of 48 3.2.3 Results A summary of the 30 day maximum normal operation cases (Cases 1 and 2), post-LOCA operation cases (Cases 3 and 4), and the maximum (all four cases) temperature for each room with either SGK05A train or SGK05B train out-of-service is shown in Table 4. This table combines the results for all 4 cases to report the maximum room temperature for each room. When the maximum temperature exceeds the 30 day temperature, this indicates that the room has reached a maximum at some point prior to the 30 day runout, and then decreased over the remaining time period of the model.

Table 4: Maximum Room Temperature Summary-All Cases Room Room#

30 day 30 day Post-Max Temp Time to Max Temp Normal (°F)

LOCA (°F)

(oF)

ESF Swor Room 1 3301 93.69 90.99 97.70 0.30 hr Post -LOCA ESF Swgr Room 2 3302 95.87 96.23 100.07 0.57 hr Post-LOCA Battery Room 1 3407 92.33 96.50 97.86 0.57 hr Post -LOCA Battery Room 2 3411 83.57 88.87 95.44 120 s Post -LOCA Batterv Room 3 3413 85.36 89.90 95.18 0.03 hr Post -LOCA Battery Room 4 3405 92.41 97.02 97.78 0.67 hr Post -LOCA DC Swbd Room 1 3408 95.65 99.73 100.63 0.70 hr Post -LOCA DC Swbd Room 2 3410 86.92 91.59 97.99 0.23 hr Post -LOCA DC Swbd Room 3 3414 90.37 95.47 98.42 0.27 hr Post -LOCA DC Swbd Room 4 3404 89.57 93.62 98.68 0.37 hr Post -LOCA Lower Cable Sprd 3501 91.23 96.82 96.87 386 hr Post -LOCA Uooer Cable Sprd 3801 86.16 100.96 100.96 696 hr Post -LOCA As can be seen from Table 4, all room temperatures remain below 104°F, which is the maximum room temperature listed in the design specifications for the Class 1 E electrical equipment and is listed in EQSD-1 as the maximum room temperature for the Class 1 E electrical equipment rooms with a single SGK05A/B train out-of-service and accident condition heat loading.

For Case 3, all of the rooms associated with the SGK05A train and the failed SGK05B train are maintained below 104 °F for the duration of the case. Figure 42 shows the results for the rooms associated with the SGK05A train and Figure 43 shows the results for the rooms associated with the SGK05B train. Note that the figure numbers in this section correspond to the figure numbers in Calculation GK-M-016.

Security Related Information Withhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 22 of 48 NAl-1929-001 R1 case 3 Junf16/2017 08:31:51 GOTHIC Vemlon 8.0{QA} - Jan 2012 File: C:\\Projects\\NAl-1929-001_R1_Case_3.Gnt

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Figure 42: Case 3 - 'A' Train Room Temperatures (Air) (3301, 3407, 3408, 3413, and 3414)

NAl-1929-001 R1 case 3 Junf16/2017 08:31:51 GOTHIC Vemlon 8.0{QA}- Jan 2012 File: C:\\Projects\\NAl-1929-001_R1_Case_3.Gnt

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Figure 43: Case 3 - 'B' Train Room Temperature (Air) (3302, 3404, 3405, 3410 and 3411)

Sesurity Related Information

'Nithhold Under 1 Q CFR 2.390 Attachment II to ET 17-0010 Page 23 of 48 For Case 4, all of the rooms associated with the SGK05B train and the failed SGK05A train are maintained below 104 °F for the duration of the case. Figure 53 shows the results for the rooms associated with the SGK05A train and Figure 54 shows the results for the rooms associated with the SGK05B train.

NAl-1929-001 R1 Case 4 Jun/16/2017 08:36:35 GOTHIC Version 8.0(QA) - Jen 2012

. File: C:\\Projects\\NAl-1929-001_R1_Case_ 4.GTH

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Figure 54: Case 4- 'B' Train Room Temperature (Air) (3302, 3404, 3405, 3410 and 3411)

Seourity Related Information

'.!'lithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 24of48 3.2.4 Room-to-Room Differential Pressure Calculation GK-M-016 calculates the pressures of the rooms in the GOTHIC model, and uses that data to compare the differential pressure across the walls of adjacent rooms. The concrete masonry unit (CMU) wall calculation is evaluated for the effects of implementation of the proposed modification to add ducts and fire dampers to allow recirculation of the air between the Class 1 E electrical equipment rooms. The CMU wall calculation evaluated a maximum differential pressure on the walls of 5 pounds per square foot. Table 5 below indicates the maximum differential pressure for each case and the affected rooms.

Table 5 - M.aximum Differential Pressure Across Walls Case Maximum DP Time {sec)

Rooms CPSF) 1 - Normal 3.74 3610 3412-3413 2 - Normal 3.38 3610 3411 - 3412 3 - Post-LOCA 4.70 10 3412-3413 4 - Post-LOCA 4.76 10 3411 -3412 As expected, the maximum differential pressure occurs across the wall between the room being pressurized (Battery Room 2 [3411] or Battery Room 3 [3413]) by the recirculation fan in service and the corridor (Room 3412) between the battery rooms. The maximum differential pressure occurs approximately 10 seconds after the recirculation fan is started, and then decreases after that. The maximum differential pressure across any one wall, for any case, is 4. 76 psf. The maximum differential pressure across the walls between Rooms 3301 and 3302.is less than 1 psf for all 4 cases. The modeled differential pressure is lower than the evaluated value of 5 psf, thus there is no concern with regards to the differential pressure. Additionally, most of the walls are significantly below this 5 psf evaluated value, creating margin in the CMU wall calculation.

3.2.5 Hydrogen Generation/Concentration The GOTHIC model includes a provision that allows the introduction a continuous gas supply into the model and track the distribution and concentration of the gas throughout the control volumes.

This provision has been utilized in Calculation GK-M-016 to determine the amount of hydrogen that might accumulate in the rooms on the 2016' level while a recirculation fan train is operating.

Table 6 provides results of the hydrogen generation/monitoring and indicates that the hydrogen concentration in any one room does not approach the 2% lower flammability safety limit of hydrogen in oxygen.

Table 6 - Maximum Hydrogen Concentration Case Maximum concentration (%)

Room Margin (%) to 2%

1 0.0030 3407 1.9970 2

0.0038 3405 1.9962 3

0.0055 3407 1.9945

-- 4 0.0066 3405 1.9934

Seourity Related Information

'Nithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 25of48 3.3 Fire Protection In those areas where a halon system is employed (switchboard rooms and ESF switchgear rooms), the HVAC system(s) serving those areas are interlocked to provide the necessary isolation upon receipt of a halon actuation signal. A halon release in either of the ESF switchgear rooms automatically isolates the portion of the Control Building Supply Air System and the Control Building exhaust serving that area and stop the associated Class 1 E electrical equipment AC train. A halon release in any one of the switchboard rooms automatically initiates isolation of that portion of the Control Building Supply Air System and Control Building Exhaust System serving that level and stops the respective Class 1 E electrical equipment AC train.

Several of the fire dampers associated with the recirculation fans are not tied to the halon system via electro-thermal links (ETL's) to isolate areas protected by halon. A spurious trip of the halon actuation system would cause these fire dampers to actuate, as well as to close the control dampers for the fans (and stopping the fans). This would prevent the recirculation fans from performing the function to circulate the cooled air from the OPERABLE Class 1 E electrical equipment AC train. However, per current plant design, such a spurious halon actuation would also stop both Class 1 E electrical equipment AC trains and close the fire dampers in the ventilation ductwork associated with the detected fire signal. This has been the normal plant design in order to isolate the rooms that experience a halon discharge and prevent dilution of the halon where the halon system actuates. In the event of a spurious halon actuation, Operations would be required to restart equipment that has been shut off, and to reposition any fire dampers that have actuated. WCGS has not experienced a spurious halon actuation since initial plant startup.

Indication of a fire from two separate fire detection circuits are required to initiate a halon actuation, thus spurious actuation of the halon system is unlikely.

3.4 Operator Actions Normal Operations (Proposed TS 3.7.20)

Required Action A.1 of the proposed TS requires the initiation of action to implement mitigating actions. The Completion Time on Required Action A.1 is immediately. Section 1.3 of the TSs defines immediately as the Required Action should be pursued without delay and in a controlled manner. The GOTHIC model assumes that the mitigating actions are completed within one hour.

The mitigating actions to be implemented require Operator action to:

1)

Travel to the NB001/NB002 switchgear rooms on 2000' level of the Control Building to start the recirculation fans that corresponds to the SGK05A/B train that is inoperable. With SGK05A train inoperable, the recirculation fans in the B train rooms are started (Rooms 3302 and 3411 ). With SGK05B train inoperable, the recirculation fans in A train rooms are started (Rooms 3301 and 3413). The recirculation fans are electrically-operated, powered from the motor control centers located in the 2000' level switchgear rooms, with the capability to be supplied power by the diesel generators. Each recirculation fan has a_

control damper which is normally closed and will prevent backflow of air through the fan when the fan is not in operation. The only action required by an Operator to start the fans is to locally switch on the fans at the motor control center. Actuation of the start circuitry

Security Related Information

'.!'lithhold Under 1Q CFR 2.39Q Attachment II to ET 17-0010 Page 26 of 48 will position the dampers accordingly and automatically start the fans when the control dampers are in the correct position.

2)

If not already completed, NK025/NK026 spare battery chargers are transferred to supply battery charging to the Class 1 E batteries and NK021/NK024 battery chargers removed from service when NK025/NK026 are supplying the charging function. In order to help ensure that the heat loading on the 2016' level is adequate to minimize room heatup, the NK025/NK026 spare battery chargers are aligned to charge the batteries and NK021/NK024 chargers are de-energized. This action maintains the battery charging function, but moves the heat load for the chargers to the 2000' level of the Class 1 E electrical equipment rooms, which are larger and have more cooling air supplied than the rooms on 2016'.

Because the charging function is maintained, there is no adverse consequence to performing this function.

3)

In the event the Control Room Ventilation Isolation System (CRVIS) is actuated and starts the Control Building Pressurization System fans (CGK04A/B) while the recirculation fans are in operation, then one train of pressurization must be secured within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This step is taken to maintain the heat loading in the Class 1 E electrical equipment rooms as low as possible. The Control Building Pressurization System draws in outside air and heats the air in the charcoal filter to minimize radioactive nuclides in the air being mixed in the Control Building. Since only one train of pressurization is required to maintain the desired positive pressure in the Control Building, securing one train of pressurization air has no adverse effect during a CRVIS actuation. This also maintains one pressurization train in reserve in the event the operating pressurization train needs to be secured. If the Control Building Pressurization trains are not actuated (normally in standby) when a Class 1 E electrical equipment A/C train is inoperable, then there is no action to take with respect to the Control Building Pressurization System.

Post-LOCA Operation For the GOTHIC model post-LOCA cases, a start time at time= 0 seconds (T=O) is assumed for the starting of the recirculation fans. This assumption is based on an operational philosophy regarding implementation timing of the mitigating actions for an inoperable Class 1 E electrical equipment A/C train. If the cooling train is determined to be inoperable following initiation of a LOCA event, the starting of the recirculation fans for the inoperable cooling train would not be initiated. Plant operators would continue to shutdown the plant utilizing the OPERABLE Class 1 E electrical equipment A/C train. If the LOCA were to occur after the recirculation fans had been placed into service, then the recirculation fans would be left operating so that both trains of Class 1 E electrical equipment would be cooled by the OPERABLE Class 1 E electrical equipment A/C train. Based on this information, a key assumption utilized in the GOTHIC model is that for the post-LOCA operation cases, the recirculation fans are started and running at time T=O. However, even if the recirculation fans were to be started after initiation of a LOCA event (or restarted if the fans lost power), as long as the fans were started and running prior to the room temperatures exceeding the assumed starting temperature of 95°F, then this assumption would be satisfied.

Security Related Information

't'!ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 27 of 48 Calculation GK-E-001, Rev. 4, "Electrical Equipment Head Loads in ESF Swgr, DC Swbd, &

Battery Rooms," identifies electrical loads tliat are considered to be "Off' in a post-LOCA scenario when only one Class 1 E electrical equipment A/C train is operating. The equipment that is powered from the safety related buses in the Class 1 E electrical equipment rooms is identified and indicated whether the calculation assumes the equipment to be "On" or "Off' at T=O, T=24 hours and T=7 days. The calculation provides the equipment that factors into the heat load at T=O, T=24 hours and T=7 days. The GOTHIC model adjusts the heat loading in the Class 1 E electrical equipment rooms based on this calculation. Primarily, this calculation takes credit for equipment turned off that would normally be off 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and 7 days after initiation of a LOCA event. Previous revisions of the calculation assumed that equipment that may be turned on during the event was on and remained on throughout the event. Section 4.C.4 of Calculation GK-E-001 details the calculation of these heat loads for post-LOCA operation with a single Class 1 E electrical equipment A/C train in operation.

3.5 Planned Modifications Design changes are in process to modify the Class 1 E Electrical Equipment A/C System and associated electrical equipment rooms to promote circulation of cool air from one Class 1 E electrical equipment A/C train to rooms associated with both Class 1 E electrical equipment trains.

The planned modifications are considered regulatory commitments to achieve the capability for one cooling train to provide adequate cooling for both trains of electrical equipment during normal and accident conditions. The planned modifications proposed by regulatory commitments with the approval of this amendment request, will be implemented under the requirements of 10 CFR 50.59 and it is expected that NRC approval will not be required.

The planned modifications include the following:

As discussed in Section 2.4 above, computer points are used to verify the DC switchboard rooms and ESF switchgear room temperatures are less than 87°F and provide an alarm on the main control board. The temperature limits established for these rooms is ::;; 90°F (this includes an allowance for instrument error of +/-3°F) with a current alarm setpoint of 87°F. The alarm setpoint on the associated temperature indicators will be lowered to 83°F.

This will provide earlier indication of potential problems with a Class 1 E electrical equipment A/C train.

Installation of two recirculation fans (with isolation dampers) and 10 wall or ceiling penetrations (with fire dampers) in the battery and switchboard Rooms. One fan and two isolation dampers will be aligned with each SGK05 cooling train 'A' and 'B'.

The recirculation fans placed in Battery Rooms 2 and 3 discharges into common ductwork utilizing the isolation dampers to direct airflow to the opposing train. See Figures 3 and 4.

The remainder of the circulating airflow path/loop travels from room-to-room through a series of wall penetrations equipped with fire dampers. See Figure 5. A return duct between Battery Rooms 1 and 4 carries the warm air back to Battery Room 1 or. 4 (depending on which SGK05 train is functioning) where there is a return duct for the functional SGK05 cooling train.

Seourity Related Information

)."/ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 28 of 48 Upon failure of a SGK05 cooling train or during pre-planned preventive maintenance, an Operator locally initiates actuation of the start circuitry that will position the dampers accordingly and automatically start the fans when the control dampers are in correct position. The recirculation fan transports cool air from the OPERABLE SGK05 cooling train to the Class 1 E electrical equipment rooms of the opposite train. In this manner, either SGK05A or SGK05B cooling train is capable of cooling both trains of Class 1 E equipment rooms.

Figure 3 below provides a schematic showing the airflow path assuming SGK05A cooling train is operating and supplying cooling to both trains of electrical equipment.

Installation of LED lighting in the Class 1 E electrical equipment rooms.

Seourity Related Information

\\Afithhold Under 10 CFR 2.390' Attachment II to ET 17-0010 Page 29of48

Security Related Information JJ'!ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 30of48 Installation of four recirculation fans with control dampers in the ESF switchgear rooms.

Depending on the cooling train that is in operation, manual Operator action will be taken (TS 3.7.20, Required Action A.1) to open the motorized control damper and will result in the start of two recirculation fans (two fans associated with each cooling train). One recirculation fan is positioned to circulate cool air from the switchgear room with the operating cooling train to the switchgear room with the nonfunctioning cooling train. The second recirculation fan is positioned to draw warm air from the switchgear room with the nonfunctioning cooling train to the operating cooling train return register. Figures 6 and 7 provides schematics of the circulating air flow path that is created depending on the train of recirculation fans in service.

Installation of LED lighting in the ESF switchgear rooms.

Security Related Information

'A'ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 31of48

Seourity Related Information tl\\'ithhold Under 1 g CFR 2.390 Attachment II to ET 17-0010 Page 32 of 48 The planned modifications would allow one Class 1 E electrical equipment A/C train to provide adequate area cooling for both trains of Class 1 E electrical equipment during normal and accident conditions while minimizing mitigating actions. The proposed TS 3.7.20 would allow LCO 3.0.6 to be applied such that support system inoperability is dealt within the Conditions and Required Actions of TS 3.7.20 (as long as safety function has not been lost). It is anticipated that the planned modifications will be completed during the Spring 2018 Refueling Outage.

3.6 Proposed Technical Specifications Section 2.1 of this Evaluation provides a detailed listing of the requested TS changes.

The application of the definition of OPERABILITY requires that associated electrical TS LCOs be declared not met upon the determination of a Class 1 E electrical equipment A/C train being nonfunctional, is overly restrictive and does not provide sufficient opportunity to restore the Class 1 E electrical equipment A/C train to a functional status resulting in an unnecessary plant shutdown. Therefore, WCNOC proposes adding new TS 3.7.20, "Class 1E Electrical Equipment A/C System," to the TSs with appropriate Completion Times, commensurate with their importance to nuclear safety. The requirements of TS 3.7.20 in conjunction with planned modifications would

Seourity Related Information U'!ithholEI UnEler 10 CFR 2.390 Attachment II to ET 17-0010 Page 33 of 48 allow one OPERABLE Class 1 E electrical equipment A/C train to provide adequate area cooling for both trains of Class 1 E electrical equipment during normal and accident conditions (with mitigating actions being required).

There is no existing or comparable TS provided in NUREG-1431, "Standard Technical Specifications - Westinghouse Plants." The lack of an existing or comparable Standard Technical Specification (STS) should not be a barrier to the review of the proposed license amendment.

Ideally, every domestic nuclear plant with a Westinghouse Nuclear Steam Supply System would have a set of plant-specific TSs that is a one-for-one match with the revision of NUREG-1431 approved for use at the time of the conversion amendment. The NRC has previously approved the addition of new TS 3.7.19 for WCNOC in Amendment No 184 (Reference 6.8) that did not have an existing STS. Proposed additions to the TSs, however, should be judged against the requirements of 10 CFR 50.36(c)(2)(ii) rather than the vendor specific STS NU REG. The four specified criterion are:

Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

NRC Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (Reference 6.9) provides a discussion of Criterion 3 that states, in part:

"It is the intent of this criterion to capture into Technical Specifications only those structures, systems, and components that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation system that are necessary for items in the primary success path to successfully function." [emphasis added]

Not every parameter, value or requirement that meets one or more of the four Criteria of 50.36(c)(2)(ii) is in the plant specific TSs or the Improved Standard Technical Specifications (ISTS) NUREGs. The current content of the ISTS NUREGs and the NRC's Safety Evaluations for ITS conversions support the principle that not all aspects of the plant's design that meet one of the four Criteria are required by regulation to be in the TSs. NRC has made subjective decisions on what requirements should be included in the TSs. The four Criteria of 50.36(c)(2(ii) are a guide for the determination of the appropriate scope of TS requirements. The fact that a requirement meets one or more of the four Criteria of 50.36(c)(2)(ii) does not necessarily mean it

Seourity Related Information

'Nithhold Under 1Q CFR 2.39Q Attachment II to ET 17-0010 Page 34 of 48 must be included in TSs unless the NRC also has determined the requirement meets the subjective criteria for inclusion in the TSs.

The Class 1 E Electrical Equipment A/C System is a support system similar to Component Cooling Water (CCW) System (ISTS 3.7.7) and Service Water System (ISTS 3.7.8) [Essential Service Water System for WCGS]. These two systems screened in under Criterion 3 as a support system to various systems which are assumed to function to mitigate various DBAs during the development of the ISTS (Reference 6.10).

The Class 1 E Electrical Equipment A/C System (support system) provides a suitable atmosphere for the Class 1 E electrical equipment (supported system that functions to mitigate various DBAs) during all modes of plant operation, including loss of preferred power and post-accident operation.

Therefore, WCNOC has determined that the Class 1 E Electrical Equipment A/C System satisfies Criterion 3of10 CFR 50.36(c)(2)(ii).

When the plant is operating in MODES 1 through 4, the applicable TS LCOs for the supported systems (TS 3.8.4 and TS 3.8.9) contain Conditions and Required Actions with very short Completion Times. Required Action A.1 of TS 3.8.4 and Required Action C.1 of TS 3.8.9 have 2-hour Completion Times for one inoperable DC electrical power subsystem and one inoperable DC electrical power distribution subsystem, respectively. Each DC electrical power subsystem, or train, contains two 125 VDC buses with each bus energized from its battery and a battery charger or spare charger. Each DC electrical power distribution subsystem, or train, contains two 125 VDC buses with each bus energized to the proper voltage from either its battery or a battery charger. Required Action A.1 of TS 3.8.9 has an 8-hour Completion Time for one inoperable AC power electrical distribution subsystem with each subsystem, or train, consisting of one 4.16 kV bus and two 480 VAC load centers as listed in TS Bases Table'B 3.8.9-1. Required Action B.1 of TS 3.8.9 has a 2-hour Completion Time for one inoperable AC vital bus subsystem with each subsystem, or train, consisting of two 120 VAC AC vital buses as listed in TS Bases Table B 3.8.9-

1. Cascading to these electrical Specifications, in the event one Class 1 E electrical equipment A/C train is declared nonfunctional, is not appropriate if electrical equipment room temperatures remain acceptable for supporting the specified safety functions. In consideration of the relative significance of declaring one Class 1 E electrical equipment A/C train nonfunctional, the imposition of entering LCO 3.0.3 and entry into a Condition/Required Action with a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is not warranted.

Proposed LCO 3.7.20 requires two Class 1 E electrical equipment A/C trains be OPERABLE. The LCO Applicability includes MODES 1, 2, 3, and 4. Although the LCO for the Class 1 E Electrical Equipment A/C System is not applicable in MODES 5 and 6, the capability of the Class 1 E Electrical Equipment A/C System to perform its necessary related support functions may be required for OPERABILITY of supported systems. The Applicability for this new support system LCO reflects the Applicability of TS 3.7.8 and associated TS Bases, "Essential Service Water (ESW) System," the heat sink for the Class 1 E electrical equipment A/C trains during post-accident operation.

Proposed TS 3.7.20 provides Conditions and Required Actions for one Class 1 E electrical equipment A/C train inoperable. Required Action A.1 of Condition A requires the initiation of of action to implement mitigating actions with a Completion Time of immediately. The proposed

Seourity Relatec:t Information

'.'-Vithholc:t Unc:ter 10 CFR 2.390 Attachment II to ET 17-0010 Page 35 of 48 Required Action A.1 is similar to TS 3. 7.10 Required Action B.2 that requires the initiation of action to implement mitigating actions. Required Action A.2 requires verifying room area temperatures are ~ 90°F within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The actions of Required Actions A.1 and A.2 assure that the initial conditions of Calculation GK-M-016* are met. The mitigating actions to be taken include opening the associated single train recirculating fans discharge damper and starting the fans corresponding with the OPERABLE Class 1 E electrical equipment A/C train and placing in service the spare battery chargers. Additionally, if the Control Building Pressurization System actuates (while in the single A/C train configuration) resulting in two trains of pressurization in operation, one train of pressurization is secured within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Required Action A.2 of Condition A requires v.erifying the Class 1 E electrical equipment room area temperatures are ~ 90°F.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, based on operating experience, to verify room area temperatures and the minimal increase in room temperatures during this time period.

Required Action A.3 of Condition A requires the Class 1 E electrical equipment A/C train be restored to OPERABLE status in 30 days. The 30 day Completion Time is based on the capability of the remaining OPERABLE Class 1 E electrical equipment A/C train to provide adequate area cooling for both trains of electrical equipment during normal and accident conditions (with mitigating actions implemented) and the low probability of an event occurring during this time period.

Additionally, Calculation GK-M-016 determined that a single Class 1 E electrical equipment A/C train is capable of maintaining for at least 30 days the temperature of the Class 1 E electrical equipment rooms below the maximum design temperature limit.

A 30 day Completion Time is consistent with TS 3. 7.11, that provides 30 days to restore an inoperable CRAGS train to OPERABLE status. The CRAGS maintains a suitable equipment environment for the Reactor Protection System cabinets, Engineered Safety Feature Actuation System cabinets, main control room indicators and controls, as well as control room personnel habitability.

Condition A provides a sufficient time to perform corrective and preventive maintenance on a Class 1 E electrical equipment A/C train without requiring unnecessary plant transients. Based on the history of maintenance activities (see Table 7 below) that have been required on the Class 1 E electrical equipment A/C trains, a Completion Time of 30 days is reasonable and will allow maintenance activities to be completed without requiring unnecessary plant transients. Procedure.

AP 22C-002, "Work Controls," specifies that TS equipment work shall not be scheduled to exceed 50% of the TS Completion Time. As such, scheduled maintenance activities typically would not exceed 15 days.

Table 7 Date/Time Date/Time Approximate Cause Nonfunctional Restored Duration 5/29/12 5/31/12 2 days 2 hrs SGK05B declared nonfunctional due to 1625 1835 degrading oil pump pressure. (Licensee Event Report (LER) 12-005-00)

Seourity Related Information Attachment II to ET 17-0010 Page 36 of 48 Date/Time Date/Time Nonfunctional Restored 6/4/12 6/6/12 0325 0505 5/6/13 5/11/13 1733 0451 6/17/13 6/21/12 1111 2220 9/11/13 9/26/13 2013 2316 10/18/13 10/21/13 1141 1915 5/15/15 5/16/15 12/23/15 12/25/15 2330 0136 8/15/16 8/16/16 0433 1131 Approximate Duration 2 days 2 hrs 4 days 9 hrs 4 days 11 hrs 15 days 3 hrs 3 days 8 hrs 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 2 days 2 hrs 1 day 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months

\\6/ithhold Under 1 Q GFR 2.39Q Cause SGK05A found tripped on low oil pressure and declared nonfunctional. Oil strainer was clogged with oil sludge and particulate matter.

(LER 12-005-00)

SGK05A declared nonfunctional due to an increasing temperature trend in the 'A' train equipment rooms. The evaporator coils were being starved of refrigerant which was consistent with blockage of thermostatic expansion valves. (LER 2013-006-01)

SGK05A oil analysis and other indicators indicated damage to the compressor.

Determined damage was the result of an inadequate chemical flush and evacuation in May 2013. (LER 2013-007-01)

SGK05A low oil level and other indicators indicated damage to the compressor.

Determined damage was the result of an inadequate chemical flush and evacuation in May 2013. (LER 2013-008-00)

SGK05A declared nonfunctional when the loss of lube oil pressure sensing to the oil pressure switch of the compressor occurred. (LER 2013-010-00)

On two separate occasions during this time period, SGK05A compressor tripped on lube oil failure indication. The compressor was restarted after pressing the manual reset on the lube oil pressure switch. The lube oil failure sensor was bypassed under a temporary modification.

SGK05B compressor tripped on lube oil failure indication. The lube oil failure sensor bypassed under a temporary modification SGK05B declared nonfunctional and removed from service when the building watch identified water on the floor in the SGK05B room. It was determined that that fan unit drain line is plugged such that the fan unit is filling with water.

Security Related Information

'.".'ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 37 of 48 If the Required Action and associated Completion Time of Condition A cannot be met, Condition B would require a plant shutdown to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If two Class 1 E electrical equipment NC trains are inoperable, LCO 3.0.3 would be entered immediately under Condition C. This ensures that the plant is placed in a MODE that minimizes accident risk.

New SR 3.7.20.1 requires, on an 18-month specified Frequency, that each Class 1 E electrical equipment NC train actuates on an actual or simulated actuation signal. The actuation signals include the CRVIS and actuations driven by the LOCA and shutdown sequencers. A CRVIS is generated by the inputs discussed in the LCO Bases for TS 3.3.7, "CREVS Actuation Instrumentation." Procedures STS KJ-001NB, "Integrated DIG and Safeguards Actuation Test-Train NB," currently verifies that the cooling trains are load shed and the sequenced back on under a simulated actuation signal. The proposed SR and associated Frequency are consistent with similar SRs and Frequencies for ESF components that receive actuation signals.

New SR 3.7.20.2 verifies that the heat removal capability of the Class 1 E electrical equipment NC trains is adequate to remove the heat load assumed during design basis accidents by a combination of monitoring and inspection methods. This SR consists of verifying the heat removal capability of the condenser heat exchanger by water flow measurement, pressure loss monitoring and visual inspection, visual inspection monitoring of the evaporator heat exchanger coils, ensuring the proper operation of major components in the refrigeration cycle, verification of unit air flow capacity, and verification that the tube plugging limits are met. The 18 month Frequency is appropriate since significant degradation of the Class 1 E Electrical Equipment NC System is not expected over this time period. The proposed SR and associated Frequency are similar to SR 3.7.11.1 forthe CRAGS.

New SR 3. 7.20.2 requires verifying each Class 1 E electrical equipment NC train (SGK05NB) has the capability to remove the assumed heat load. The condenser heat exchangers on the cooling train employ ESW to remove heat from the refrigeration cycle. The ability of the system to reject the design heat load is directly dependent on the capacity of the condenser heat exchangers to reject the design coil load combined with compressor work input. Therefore, the heat rejected from the refrigeration cycle of the respective equipment is exchanged with the Ultimate Heat Sink.

This places the condenser units of each air conditioner under the scope of NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment (Generic Letter 89-13)." Generic Letter 89-13 was issued due to operating experience and studies that led the NRC to question* the compliance of the service water systems in nuclear power plants that were required to meet the minimum requirements of 10 CFR 50 Appendix A, General Design Criteria (GDC) 44, '!Cooling water;" GDC 45, "Inspection of cooling water system," GDC 46, "Testing of cooling water system," and quality assurance requirements. Generic Letter 89-13 requested plants perform five recommended.actions or provide a.ssurance that alternative programs satisfy the heat removal requirements of the Service Water System. Subsequently, the NRC issued Generic Letter 89-13, Supplement 1, that provided questions and answers from four workshops conducted on the generic letter. Enclosure 1 to Supplement 1, Section Ill, "Action II - Heat Transfer Testing," Subsections A, "Testing Method," Questions 4, 5, and 6 related to acceptable testing methods.

SeGurity Related Information

'*"lithhold Under 10 CFR 2.390

Attachment II to ET 17-0010 Page 38of48 WCNOC letter ET 94-0012 (Reference 6.16), provided an updated response to Generic Letter 89-13. This letter states, in part:

"It was also determined that ten of the 32 heat exchangers in the program were not well suited to heat transfer verification testing due to their unique design applications. These were the Diesel Generator Heat Exchangers (EKJ03A & B, EKJ04A & B, EKJ06A & B),

the Control Room Air Conditioning Units (SGK04A & B), and the Class 1/E Air Conditioning Units (SGK05A & B). The Diesel Generator Heat Exchangers carry heat loads which are not easily determined by field instruments due to temperature modulating valves and the Control Room and Class 1/E Room Air Conditioning Units are water-to-freon heat exchangers which involve quantifying phase changes, enthalpy changes, and transient flow patterns. For these reasons, mechanical and/or chemical cleaning is performed for corrosion or deposit removal. Also, this group of heat exchangers is visually inspected for erosion, corrosion, biofouling, pitting, and wall thinning. This maintenance program is currently performed once per refueling cycle on these particular components."

A review of Electric Power Research Institute (EPRI) TR-107397, 1998 Final Report, "Service Water Heat Exchanger Testing Guidelines," indicates that the design of the Class 1 E electrical equipment A/C trains make heat transfer performance testing of these units impractical.

Reference 6.11 requested a TS interpretation regarding SR 3. 7.11.1 subsequent to the issuance of non-cited violation 05000482/2012005-04, "Failure to Perform Sufficient Control Room Air Conditioning Testing to Satisfy Technical Specification Surveillance Requirements." Reference 6.12 provided the NRC response to the request and concluded the following:

"As discussed in the licensee's request for TS interpretation, the procedures implement heat exchanger inspection and cleaning, verify proper operation of the major components in the refrigeration cycle, verify unit air flow capacity, and measure ESW system flow rate. The licensee's procedures provide an acceptable alternative to a heat transfer test, which is impractical to perform, on SGK04A/B. The NRC staff concluded that the licensee's procedures implementing the SR provide reasonable assurance that the CRAGS is operable. Therefore, based upon the information provided by the licensee and the staffs position provided in GL 89-13, Supplement 1, the NRC staff concludes that the implementing procedures used by the licensee meet the intent of SR 3.7.11.1."

This interpretation is also applicable to the Class 1 E electrical equipment A/C trains due to the design being similar to the CRAGS. As such, the procedures for implementing new SR 3.7.20.2 verify the heat removal capability of the condenser heat exchanger by water flow measurement, pressure loss monitoring and visual inspection, visual inspection monitoring of the evaporator heat exchanger coils, ensuring the proper operation of major components in the refrigeration cycle, verification of unit air flow capacity, and verification that the tube plugging limits are met.

3. 7 Differences from the Callaway Plant It is expected that the Callaway Plant will submit an LAR in conjunction with WCNOC within the same period of time or shortly thereafter. The differences below are based on discussions with

Sesurity Related Information

'Nithhold Under 1 O CFR 2.390 Attachment II to ET 17-0010 Page 39of48 Callaway Plant personnel.

During the August 25, 2016 pre-application meeting, the NRC requested that the differences between the two plants be identified.

The ESF switchgear rooms on Control Building 2000' level and the DC switchboard rooms on 2016' level are protected by halon injection systems in case of a fire in these areas for WCGS.

The Callaway Plant has removed the halon injection systems from the rooms on the 2016' level. The WCGS Fire Protection Program is based on 10 CFR 50 Appendix R, and the Callaway Plant Fire Protection Program is based on NFPA-805.

The basic premise behind the proposed modifications is the same at both WCNOC and the Callaway Plant. Electric-motor-powered recirculation fans are utilized to move cool air from the electrical equipment rooms with an OPERABLE SGK05 train to the equipment rooms with an inoperable SGK05 train. The heated air is primarily transferred via the recirculation fans from the non-cooled rooms back to the return ductwork of the OPERABLE cooling train. It is expected that the fans/motors will be similar, or sized similarly. Transfer paths between the Class 1 E electrical equipment rooms will be created, with a means to contain any fires in these rooms to the room/area where the fire is located (via fire dampers, etc.). However, the location and size of the ductwork/transfer paths will be different between the two plants.

There are GOTHIC modeling differences associated with the plant specific implementation of the proposed modification. There are two specific differences that may be described.

The first difference is the Class 1 E electrical equipment room temperature assumed for the post-LOCA cases. WCNOC has utilized 95°F as the initial temperature and Callaway has planned to use 90°F. This is further discussed in Section 3.2.2 above.

The second difference is the start time of the recirculation fans for the post-LOCA cases.

WCNOC has the fans starting at time T=O, while the Callaway plant plans to start the fans at T=30 minutes. This is further discussed in Section 3.2.2 above.

SR 3.7.20.1 and SR 3.7.20.2 specify a Frequency of "18 months" for WCGS and "In accordance with the Surveillance Frequency Control Program" for the Callaway Plant.

(Callaway Plant has adopted the provisions specified in TSTF-425, Rev. 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF (Risk-Informed TSTF) Initiative 5b,"

as approved via Amendment No. 202 to the Callaway Plant Operating License.)

Summary New TS 3.7.20 is consistent with the requirements associated with TS 3.7.8 for the ESW System and with TS 3.7.11 for CRAGS, where appropriate. Incorporation of TS 3.7.20 resolves the three issues involving TS Section 1.1 - OPERABILITY, application of LCO 3.0.6 and the SFDP, and temporary waiver of the single failure criterion while operating under a TS Condition that were identified in September, 2010. The proposed 30 day Completion Time of Condition A for one inoperable Class 1 E electrical equipment A/C train is based on a plant specific GOTHIC calculation and provides a reasonable time for major maintenance activities. Use of LCO 3.0.6 and the SFDP is acceptable since the Class 1 E Electrical Equipment A/C System will be incorporated in its own LCO within the TS and the use of LCO 3.0.6 during entry into the new TS

Seourity Related Information

'Nithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 40 of 48 3.7.20, Condition A, is no less restrictive than the other current TS requirements allowing the use of LCO 3.0.6. As both Class 1 E electrical equipment A/C trains are in service during normal operation, new TS 3.7.20 will facilitate preventative maintenance activities and should result in improved reliability of the system.

The Completion Times will provide reasonable opportunity to restore a Class 1 E electrical equipment A/C train to OPERABLE status considering the complexity of the Class 1 E electrical equipment A/C trains, while avoiding inherent risk associated with a plant transient or shutdown, which would likely occur if the highly restrictive supported system TSs were applied (i.e., entry into LCO 3.0.3 for two inverters inoperable). Based on the above, WCNOC believes the proposed TS is commensurate with the Class 1 E Electrical Equipment A/C System's importance to safety.

The proposed TSs in conjunction with planned modifications will minimize challenges to plant

systems and the plant operators, facilitate maintenance activities, as well as enhancing plant safety.

4.0 REGULATORY EVALUATION

This section addresses the standards of 10 CFR 50.92 as well as the applicable regulatory requirements and acceptance criteria.

The proposed amendment would add new Technical Specification (TS) 3.7.20, "Class 1E Electrical Equipment Air Conditioning (A/C) System," to the Wolf Creek Generating Station (WCGS) TSs. New TS 3.7.20 will include the Limiting Condition for Operation (LCO) statement, Applicability during which the LCO must be met, ACTIONS (with Conditions, Required Actions, and Completion Times) to be applied when the LCO is not met, and Surveillance Requirements (SRs) (with specified Frequencies) to periodically demonstrate that the LCO is met for the Class 1 E Electrical Equipment A/C System trains. Additionally, TS Table of Contents page iii is revised to reflect the incorporation of new TS 3.7.20.

The proposed license amendment includes regulatory commitments to achieve the capability for one OPERABLE Class 1 E electrical equipment A/C train to provide adequate cooling for both trains of electrical equipment during normal and accident conditions by design changes. The planned modifications proposed by regulatory commitments will be implemented under the requirements of 10 CFR 50.59 and it is expected that NRC approval will not be required.

4.1 Applicable Regulatory Requirements/Criteria Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include Technical Specifications (TSs) as part of the license. The TSs ensures the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The U.S. Nuclear Regulatory Commission's (NRC's) requirements related to the content of the TSs are contained in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR 50.36) which requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2)

Sesurity Related Information Y'!ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 41of48 limiting conditions for operation; (3) surveillance requirements per 10 CFR 50.36(c)(3); (4) design features; and (5) administrative controls.

The following regulatory requirements and guidance documents also apply to the Class 1 E Electrical Equipment A/C System:

GDC 2 requires that SSCs important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions.

GDC 4 requires that SSCs important to safety be designed to accommodate the effects of, and to be compatible with, the environmental conditions associated with the normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents.

These SSCs shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, discharging fluids that may result from equipment failures, and from events and conditions outside the nuclear power plants.

However, dynamic effects *,associated with postulated pipe ruptures.in nuclear power plants may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the prob.ability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.

The following regulatory requirements and guidance documents apply to the electrical equipment supported by the Class 1 E Electrical Equipment A/C System:

GDC 13 requires that instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems.

GDC 17 requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of SSCs that are important to safety. The onsite system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure. The offsite power system is required to be supplied by two physically indepe*ndent Circuits that are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. In addition, this criterion requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of loss of power from the unit, the offsite transmission network, or the onsite power supplies.

GDC 18 requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.

GDC 20 requires that the protection system(s) shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity'control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of

Seourity Related Information

'l\\fithhold Under 1Q GFR 2.39Q Attachment II to ET 17-0010 Page 42 of 48 anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

GDC 21 requires that the protection system(s) shall be designed for high functional reliability and testability.

GDC 22 through GDC 25 and GDC 29 require various design attributes for the protection system(s), including independence, safe failure modes, separation from control systems, requirements for reactivity control malfunctions, and protection against anticipated operational occurrences.

10 CFR 50.63, "Loss of all alternating current power," requires that each light-water-cooled nuclear power plant licensed to operate must be able to withstand for a specified duration and recover from a station blackout (SBO)

Regulatory Guide 1.22 discusses an acceptable method of satisfying GDC 20 and GDC 21 regarding the periodic testing of protection system actuation functions. These periodic tests should duplicate, as closely as practicable, the performance that is required of the actuation devices in the event of an accident.

10 CFR 50.55a(h) requires that the protection systems meet IEEE 279-1971. Section 4.2 of IEEE 279-1971 discusses.the general functional requirement for protection systems to assure they satisfy the single failure criterion.

There will be no changes to the Class 1 E Electrical Equipment A/C System such that compliance with any of the above regulatory requirements would come into question.

4.2 Precedent Provided below is a comparison between the WCGS Class 1 E Electrical Equipment A/C System and the ESF cooling systems described in the TS of the Joseph M. Farley Nuclear Plant (FNP)

Unit 1 and Unit 2. A review of the FNP license amendment request (Reference 6.13), FNP response to a request for additional information (Reference 6.14 ), and FNP Amendment Nos. 176 and 169 (Reference 6.15) was performed for comparison to an approved TS for a support system providing room cooling. The amendments for FNP were approved in June 2008. This comparison demonstrates the differences between cooling systems and what has been previously approved by the NRC staff.

In Reference 6.13 and Reference 6.14, FNP identified that an operations procedure provides guidance to open the door for the Auxiliary Building DC Switchgear I Battery Charger Rooms to place the swing room cooler in service. In Reference 6.15, the NRC acknowledged in the Safety Evaluation (Section 3.0) the use of procedural actions taken upon declaring the LCO not met and entry into the applicable Condition/Required Action to assure the compensatory measure is taken.

For WCNOC, the mitigating actions to be taken upon declaring the LCO not met are identified in plant procedures.

Seourity Relateel Information

'A'ithholel Uneler 10 CFR 2.390 Attachment II to ET 17-0010 Page 43of48 FNP TS 3.7.19, "Engineered Safety Feature (ESF) Room Coolers," serves the same purpose as the new WCGS TS 3.7.20, "Class 1 E Electrical Equipment Air Conditioning (A/C) System."

The FNP ESF Room Coolers provide cooling to ESF equipment rooms during accident, and post-accident conditions. The ESF Room Coolers supplement the normal HVAC system in cooling certain rooms during normal operations. The safety related Service Water System supplies water to the cooling coils for ESF Room Coolers.

The WCGS Class 1 E electrical equipment A/C trains cool the Class 1 E electrical equipment rooms during normal plant operations and during accident and post-accident conditions. Each train is normally aligned to cool only the equipment associated with its emergency load group.

The Class 1 E electrical equipment A/C trains are operated in a continuous recirculation mode to maintain the ESF switchgear room, the battery rooms, and the DC switchboard rooms using either normal service water or the Essential Service Water System as a heat sink.* The Class 1 E Electrical Equipment A/C System does not service other ESF component rooms. Normal ESF switchgear room cooling is lost when the associated Class 1 E electrical equipment A/C train is inoperable.

The FNP ESF Room Coolers are designed to maintain the ambient air temperature within the continuous-duty rating of the ESF equipment served by the system. Each equipment room is cooled by a fan cooler and associated Service Water system which is powered from the same ESF train as that associated with the equipment in the room. Thus, a power failure or other single failure to one Room Cooler train will not prevent the cooling of redundant ESF equipment in the other train.

The design basis of the WCGS Class 1 E Electrical Equipment A/C System is to maintain temperature in the Class 1 E electrical equipment rooms to assure OPERABILITY of associated electrical equipment. The Class 1 E Electrical Equipment A/C System is designed so that the single failure of an active component coincident with a OBA will not impair the ability of the supported systems powered by the electrical equipment to fulfill their safety functions. Thus, a power failure or other single failure to one Class 1 E electrical equipment A/C train will not prevent the cooling of redundant electrical equipment in the other train.

For the FNP ESF Room Coolers, in addition to a manual start capability, automatic cooling of each ESF equipment room is initiated by one of two possible signals. Room coolers for the Auxiliary Building DC Switchgear 1 Battery Charger Rooms, and Load Control Center D and E rooms, start upon receipt of a high temperature signal from the associated room. Room coolers for each ESF pump room start upon receipt of a pump running signal. These two signals ensure that safety related cooling is provided to ESF equipment.

The WCGS Class 1 E electrical equipment A/C trains are normally operating using normal service water. The ESW System is actuated upon receipt of a safety injection (SI) signal, a low suction pressure on the auxiliary feedwater pumps, or loss of offsite power. The Class 1 E electrical equipment A/C trains are automatically started upon receipt of a CRVIS, by the LOCA sequencer and by the shutdown sequencer. A CRVIS is initiated by the control room ventilation radiation monitors, fuel building ventilation isolation signal, containment isolation

Security Related Information

'A'ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 44of48 phase A, containment atmosphere radiation monitors, containment purge exhaust radiation monitors, or manually.

The FNP ESF Room Cooler system is seismic category I and remains operational during and after a safe shutdown earthquake.

The WCGS Class 1 E Electrical Equipment A/C System is seismic category I and remains operational during and after a safe shutdown earthquake.

Additionally, there are some differences in the TSs proposed by WCNOC versus the TSs approved for FNP. These differences include the following:

WCNOC is proposing an LCO that requires two trains to be OPERABLE with an Applicability of MODES 1, 2, 3 and 4.

The Required Actions for one train inoperable include initiating action to implement mitigating action to maintain room temperatures :s; 90°F immediately.

An additional Required Action is to verify room area temperatures :s; 90°F within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter.

WCNOC is proposing a Completion Time of 30 days to restore the inoperable Class 1 E electrical equipment A/C train to OPERABLE status. The 30 day Completion Time is based on the capability of the remaining OPERABLE Class 1 E electrical equipment A/C train to provide adequate area cooling for both trains of electrical equipment during normal and accident conditions (with mitigating actions implemented) and the low probability of an event occurring during this time period.

WCNOC is proposing a separate Condition for two Class 1 E electrical equipment A/C trains inoperable with a Required Action to enter LCO 3.0.3. This Condition is consistent with TS 3.7.11.

WCNOC is proposing a Surveillance Requirement to verify by testing and inspection that each Class 1 E electrical equipment A/C train has the capability to remove the assumed heat load in lieu of a valve verification surveillance.

4.3 No Significant Hazards Consideration Determination WCNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No

Sesurity Related Information V'!ithhold Under 10 GFR 2.390 Attachment II to ET 17-0010 Page 45of48 The proposed addition of TS 3.7.20 creates a LCO for the Class 1 E Electrical Equipment A/C System that is required to support the TS Class 1 E electrical equipment. The 30 day Completion Time to restore an inoperable Class 1 E electrical equipment A/C train to OPERABLE status is consistent with the Control Room Air _Conditioning System (CRAGS) and is supported by a plant specific calculation. The Class 1 E Electrical Equipment A/C Systems' actuation, operation, or failure is not an initiator to any accident previously evaluated.

As a result, the probability of an accident previously evaluated is not significantly increased. Conversely, the proposed change provides a period of time to recover an unexpected loss of cooling capability with one OPERABLE Class 1 E electrical equipment A/C train providing adequate area cooling for both trains of Class 1 E electrical equipment during normal and accident conditions (with mitigating actions being required).

Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed to the protection systems. The same Reactor Trip System (RTS) and Engineered Safety Feature Actuation System (ESFAS) instrumentation will continue to be used. The protection systems will continue to function in a manner consistent with the plant design basis. The proposed change will not adversely affect accident initiators or precursors nor adversely alter the design assumptions and conditions of the facility or the manner in which the plant is operated and maintained with respect to such initiators or precursors.

The proposed change will not alter or prevent the capability of structures, systems, and components (SSCs) to perform their intended functions for mitigating the consequences of an accident and meeting applicable acceptance limits.

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

2.

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

Response: No No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this amendment. No new or different accidents result from addition of the proposed specification. The Class 1 E electrical equipment A/C trains maintain the capability to perform their specified safety function. The proposed license amendment includes regulatory commitments to achieve the capability for one OPERABLE Class 1 E electrical equipment A/C train to provide adequate cooling for both trains of electrical equipment during normal and accident conditions by design changes.

The planned modifications proposed by regulatory commitments will be implemented under the requirements of 10 CFR 50.59 and it is expected that NRC approval will not be required.

The proposed amendment will not alter the design or performance of the 7300 Process Protection System, Nuclear Instrumentation System, Solid State Protection System, Balance of Plant Engineered Safety Features Actuation System, Main Steam and

Seourity Related Information

'J'.'ithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 46 of 48 Feedwater Isolation System, or Load Shedder and Emergency Load Sequencers used in the plant protection systems.

The proposed change adds requirements in the TSs that were previously located in plant procedures.

One OPERABLE Class 1 E electrical equipment NC train is capable of providing adequate area cooling for both trains of Class 1 E electrical equipment during normal and accident conditions (with mitigating actions being required). The change does not have a detrimental impact on the manner in which plant equipment operates or responds to an actuation signal.

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

3.

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

Response: No The proposed specification allows for a period of time in which one Class 1 E electrical equipment NC train is capable of providing adequate area cooling for both trains of Class 1 E electrical equipment during normal and accident conditions (with mitigating actions being required). The proposed change does not impact accident offsite dose, containment pressure or temperature, Emergency Core Cooling System settings or Reactor Protection System settings, or any other parameter that could ~ffect a margin of safety. The margin of safety is* enhanced by periodically verifying the area room temperatures are maintained within limit while one Class 1 E electrical equipment NC train is inoperable and allowing a reasonable period to perform preventive and corrective maintenance thus increasing system reliability.

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

Based on the above evaluation, WCNOC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

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

5.0 ENVIRONMENTAL CONSIDERATION

WCNOC has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the

Seourity Related Information

'Nithhold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 47of48 types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environment impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 Letter KMLNRC 82-230, from G. L. Koester, KG&E, to USNRC, "Draft Technical Specifications," August 5, 1982.

6.2 Letter ULNRC-564, from E. K. Dille, Union Electric Company, to USNRC, "Callaway Plant Technical Specifications," February 29, 1982.

6.3 Letter from H. L. Thompson, USNRC, to G. L. Koester, KGE, "Issuance of Facility Operating License NPF Wolf Creek Generating Station, Unit 1," June 4, 1985.

6.4 Letter from J. N. Donohew, USNRC, to 0. L. Maynard, WCNOC, "Conversion to Improved Technical Specifications for Wolf Creek Generating Station - Amendment No. 123 to Facility Operating License No. NPF-42 (TAC NO. M98738)," March 31, 1999. (ADAMS Accession Number ML022050061) 6.5 Letter from D. A. Powers, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station NRC Problem Identification and Resolution Inspections Report 05000482/2012007 and Notice of Violation," July 5, 2012. (ADAMS Accession Number ML12191A269) 6.6 Letter from N. O'Keefe, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Integrated Inspection Report 05000482/2012004," November 9, 2012. (ADAMS Accession Number ML12314A296) 6.7 NRC Memorandum from S. Bahadur, to K. Kennedy, "Final Response to Task Interface Agreement 2013-03, Fort Calhoun Station Design Basis Reconstitution of Containment Internal Structures with GOTHIC Analysis," March 28, 2014. (ADAMS Accession Number ML14091A815) 6.8 Letter from B. K. Singal, USNRC, to R. A. Muench, WCNOC, "Wolf Creek Generating Station - Issuance of Amendment Re: Revision to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," and TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," and Addition of New TS 3.7.19, "Secondary System Isolation Valves (SSIVs)" (TAC NO. MD9469)," July 31, 2009.

(ADAMS Accession Number ML091540083) 6.9 Federal Register Notice (58 CR 39132), "Final Policy Statement on Technical Specification Improvements," July 22, 1993.

Security Related Information * 'ft.'itl:'thold Under 10 CFR 2.390 Attachment II to ET 17-0010 Page 48 of 48 6.10 Letter from Westinghouse Owners Group letter OG-87-43, "Westinghouse Owners Group MERITS Program Phase II, Task 5 Criteria Application Topical Report," November 12, 1987.

6.11 Letter WO 14-0038 from R. A. Smith, WCNOC, to USNRC, "Request for Interpretation of Technical Specification 3.7.11, "Control Room Air Conditioning System (CRACS)," March 21, 2014. (ADAMS Accession Number ML14091A244) 6.12 Letter from C.F. Lyon, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station

- Interpretation of Technical Specification Surveillance Requirement 3.7.11.1, "Verify each CRACS train has the capability to remove the assumed heat load" (TAC NO. MF3665),"

May 28, 2014. (ADAMS Accession Number ML14106A362) 6.13 Southern Company Operating Corporation Letter NL-07-0117, "Joseph M. Farley Nuclear Plant - Units 1 and 2 Technical Specifications Amendment Request Engineered Safety Feature Room Coolers," June 5, 2007. (ADAMS Accession Number ML071560605) 6.14 Southern Company Operating Corporation Letter NL-08-0961, "Joseph M. Farley Nuclear Plant - Units 1 and 2 Technical Specifications Amendment Request Engineered Safety Feature Room Coolers Request for Additional Information," June 20, 2008. (ADAMS Accession Number ML081720349) 6.15 Letter from R. A. Jervey, USN RC, to J. R. Johnson, FNP, "Joseph M. Farley Nuclear Plant, Units 1 and 2 RE: Issuance of Amendments - Addition of Engineered Safety Features Room Cooler Technical Specification (TAC NOS. MD5778 and MD5779)," June 27, 2008.

(ADAMS Accession Number ML081340522) 6.16 Letter ET 94-0012 from F. T. Rhodes, WCNOC, to USNRC, "Updated Response to Generic Letter 89-13," February 18, 1994.

Attachment Ill to ET 17-0010 Page 1 of 5 ATTACHMENT Ill PROPOSED TECHNICAL SPECIFICATION CHANGES {MARK-UP)

Attachment Ill to ET 17-0010 Page 2 of 5 TABLE OF CONTENTS 3.7 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.7.7 3.7.8 3.7.9 3.7.10 3.7.11 3.7.12 3.7.13 3.7.14 3.7.15 3.7.16 3.7.17 3.7.18 3.8 3.8.1 3.8.2 3.8.3 3.8.4 3.8.5 3.8.6 3.8.7 3.8.8 3.8.9 3.8.10 3.9 3.9.1 3.9.2 3.9.3 3.9.4 3.9.5 3.9.6 PLANT SYSTEMS.................................................................................... 3.7-1 Main Steam Safety Valves (MSSVs)................................................ 3.7-1 Main Steam Isolation Valves (MSIVs) and MSIV Bypass Valves..... 3.7-5 Main Feedwater Isolation Valves (MFIVs) and Main Feedwater Regulating Valves (MFRVs) and MFRV Bypass Valves............ 3.7-9 Atmospheric Relief Valves (ARVs)................................................... 3.7-13 Auxiliary Feedwater (AFW) System.................................................. 3.7-15 Condensate Storage Tank (CST)..................................................... 3.7-18 Component Cooling Water (CCW) System...................................... 3.7-20 Essential Service Water System (ESW)........................................... 3.7-22 Ultimate Heat Sink (UHS)................................................................. 3.7-24 Control Room Emergency Ventilation System (CREVS)................. 3.7-26 Control Room Air Conditioning System (CRACS)............................ 3. 7-29 Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System - Not Used................................................. 3.7-32 Emergency Exhaust System (EES).................................................. 3.7-33 Penetration Room Exhaust Air Cleanup System (PREACS) -

Not Used..................................................................................... 3.7-37 Fuel Storage Pool Water Level......................................................... 3. 7-38 Fuel.Storage Pool Boron Concentration........................................... 3.7-39 Spent Fuel Assembly Storage.......................................................... 3.7-41 Secondary Specific Activity............................................................... 3. 7 -43 ELECTRICAL POWER SYSTEMS........................................................... 3.8-1 AC Sources - Operating.................................................................... 3.8-1 AC Sources - Shutdown.................................................................... 3.8-18 Diesel Fuel Oil, Lube Oil, and Starting Air........................................ 3.8-21 DC Sources - Operating.................................................................... 3.8-24 DC Sources - Shutdown................................................................... 3.8-28 Battery Cell Parameters.................................................................... 3.8-30 Inverters - Operating......................................................................... 3.8-34 Inverters - Shutdown......................................................................... 3.8-35 Distribution Systems - Operating...................................................... 3.8-37 Distribution Systems - Shutdown...................................................... 3.8-39 REFUELING OPERATIONS..................................................................... 3.9-1 Boron Concentration......................................................................... 3.9-1 Unborated Water Source Isolation Valves....................................... 3.9-2 Nuclear Instrumentation.................................................................... 3.9-3 Containment Penetrations................................................................ 3.9-5 Residual Heat Removal (RHR) and Coolant Circulation - High Water Level.................................................... 3.9-7 Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level...................................................... 3.9-9 Wolf Creek - Unit 1 iii Amendment No. 123, 132, 134, 163, 171, 47-7, 184

Attachment Ill to ET 17-0010 Page 3 of5 SS IVs 3.7.19 SURVEILLANCE REQUIREMENTS SR 3.7.19.1 SR 3.7.19.2 SR 3.7.19.3 Wolf Creek - Unit 1 SURVEILLANCE FREQUENCY Verify each automatic SSIV in the flow path is in the 31 days correct position.

Verify the isolation time of each automatic SSIV is In accordance with within limit.

the lnservice Testing Program*

Verify each automatic SSIV in the flow path actuates 18 months to the isolation position on an actual or simulated actuation signal.

3.7-45 Amendment No. 184 I

Attachment Ill to ET 17-0010 Page 4 of 5 3.7 PLANT SYSTEMS Class 1 E Electrical Equipment Air Conditioning (A/C) System 3.7.20

3. 7.20 Class 1 E Electrical Equipment Air Conditioning (A/C) System LCO 3.7.20 Two Class 1 E electrical equipment A/C trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One Class 1 E electrical A.1 Initiate action to Immediately equipment A/C train implement mitigating inoperable.

actions.

AND A.2 Verify room area 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months temperatures::;; 90°F.

AND Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter AND A.3 Restore Class 1 E 30 days electrical equipment A/C train to 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 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 C.

Two Class 1 E electrical C.1 Enter LCO 3.0.3.

Immediately equipment A/C trains inoperable.

(continued)

Wolf Creek - Unit 1 3.7-46 Amendment No. XX

Attachment Ill to ET 17-0010 Page 5 of 5 Class 1 E Electrical Equipment Air Conditioning (A/C) System 3.7.20 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 7.20.1 Verify each Class 1 E electrical equipment A/C train 18 months actuates on an actual or simulated actuation signal.

SR 3. 7.20.2 Verify each Class 1 E electrical equipment A/C train 18 months has the capability to remove the assumed heat load.

Wolf Creek-Unit 1 3.7-47 Amendment No. XX

Attachment IV to ET 17-001 O Page 1 of 4 ATTACHMENT IV REVISED TECHNICAL SPECIFICATION PAGES

TABLE OF CONTENTS 3.7 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.7.7 3.7.8 '

3.7.9 3.7.10 3.7.11 3.7.12 3.7.13 3.7.14 3.7.15 3.7.16 3.7.17 3.7.18 3.7.19 3.7.20 3.8 3.8.1 3.8.2 3.8.3 3.8.4 3.8.5 3.8.6 3.8.7 3.8.8 3.8.9 3.8.10 3.9 3.9.1 3.9.2 3.9.3 3.9.4 3.9.5 3.9.6 PLANT SYSTEMS................................................................................... 3.7-1 Main Steam Safety Valves (MSSVs)............................................... 3.7-1 Main Steam Isolation Valves (MSIVs) and MSIV Bypass Valves.... 3.7-5 Main Feedwater Isolation Valves (MFIVs) and Main Feedwater Regulating Valves (MFRVs) and MFRV Bypass Valves............ 3.7-9 Atmospheric Relief Valves (ARVs).................................................. 3.7-13 Auxiliary Feedwater (AFW) System................................................. 3.7-15 Condensate Storage Tank (CST).................................................... 3.7-18 Component Cooling Water (CCW) System..................................... 3.7-20 Essential Service Water System (ESW).......................................... 3.7-22 Ultimate Heat Sink (UHS)................................................................ 3.7-24 Control Room Emergency Ventilation System (CREVS)................. 3.7-26 Control Room Air Conditioning System (CRACS)........................... 3.7-29 Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System - Not Used................................................ 3.7-32 Emergency Exhaust System (EES).. ~.............................................. 3.7-33 Penetration Room Exhaust Air Cleanup System (PREACS)-

Not Used................................................................................... 3.7-37 Fuel Storage Pool Water Level........................................................ 3.7-38 Fuel Storage Pool Boron Concentration.......................................... 3.7-39 Spent Fuel Assembly Storage......................................................... 3.7-41 Secondary Specific Activity.............................................................. 3.7-43 Secondary System Isolation Valves (SSIVs)................................... 3.7-44 Class 1 E Electrical Equipment Air Conditioning (A/C) System....... 3.7-46 ELECTRICAL POWER SYSTEMS.......................................................... 3.8-1 AC Sources - Operating................................................................... 3.8-1 AC Sources - Shutdown............... ;.......................... '........................ 3.8-18 Diesel Fuel Oil, Lube Oil, and Starting Air....................................... 3.8-21 DC Sources - Operating.................................................................. 3.8-24 DC Sources - Shutdown.................................................................. 3.8-28 Battery Cell Parameters................................................................... 3.8-30 Inverters - Operating......................................................................... 3.8-34 Inverters - Shutdown........................................................................ 3.8-35 Distribution Systems - Operating..................................................... 3.8-37 Distribution Systems - Shutdown..................................................... 3.8-39 REFUELING OPERATIONS................................................................... 3.9-1 Boron Concentration........................................................................ 3.9-1 Unborated Water Source Isolation Valves....................................... 3.9-2 Nuclear Instrumentation.......................... _......................................... 3.9-3 Containment Penetrations............................................................... 3.9-5 Residual Heat Removal (RHR) and Coolant Circulation - High Water Level................................................... 3.9-7 Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level.................................................... 3.9-9 Wolf Creek - Unit 1 iii Amendment No. 123, 132, 134, 163, 171, 177, 184,

3. 7 PLANT SYSTEMS Class 1 E Electrical Equipment Air Conditioning (A/C) System 3.7.20 3.7.20 Class 1 E Electrical Equipment Air Conditioning (A/C) System LCO 3.7.20 Two Class 1 E electrical equipment A/C trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One Class 1 E electrical A.1 Initiate action to Immediately equipment A/C train implement mitigating inoperable.

actions.

AND A.2 Verify room area 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months temperatures :=; 90°F.

AND Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter AND A.3 Restore Class 1 E 30 days electrical equipment A/C train to 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 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 C.

Two Class 1 E electrical C.1 Enter LCO 3.0.3.

Immediately equipment A/C trains inoperable.

(continued)

Wolf Creek - Unit 1 3.7-46 Amendment No.

I

Class 1 E Electrical Equipment Air Conditioning (A/C) System 3.7.20 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.20.1 Verify each Class 1 E electrical equipment A/C train actuates on an actual or simulated actuation signal.

SR 3. 7.20.2 Verify each Class 1 E electrical equipment A/C train has the capability to remove the assumed heat load.

Wolf Creek - Unit 1 3.7-47 FREQUENCY 18 months 18 months Amendment No.

Attachment V to ET 17-0010 Page 1 of 6 ATTACHMENT V PROPOSED TS BASES CHANGES (for information only)

Attachment V to ET 17-001 O Page 2 of 6 Class 1 E Electrical Equipment Air-Conditioning (A/C) System B 3.7.20 B 3. 7 PLANT SYSTEMS B 3.7.20 Class 1 E Electrical Equipment Air Conditioning (A/C) System BASES BACKGROUND The Class 1 E electrical equipment air conditioning (A/C) trains provide a suitable environment for the Class 1 E electrical equipment. These air-conditioning trains provide temperature control for the Engineered Safety Features (ESF) switchgear room components, DC switchboard room components, and NK battery room components. The specific rooms supplied by the pass '1 E electrical equipment A/C trains are:

I SGK05A SGK05B SWBD RM N0.1 (3408)

SWBD RM NO. 4 (3404)

SWBD RM NO. 3 (3414)

SWBD RM NO. 2 (3410)

Battery RM NO. 1 (3407)

Battery RM NO. 4 (3405)

Battery RM NO. 3 (3413)

Battery RM NO. 2 (3411)

ESF SWGR RM NO. 1 (3301)

ESF SWGR RM NO. 2 (3302)

The Class 1 E electrical equipment A/C trains consist of two independent trains that provide cooling of recirculated air in the rooms associated with

that train. Each train consists of a prefilter, ~elf-contained refrigeration system (using normal service water or essential service water (ESW) as a heat sink), centrifugal fans, instrumentation, and controls to provide for electrical equipment room temperatur~ control.

The Class 1 E electrical equipment A/C trains have emergency operation functions and also operate during normal unit operation. Each train is normally aligned to cool only the equipment associated with its emergency load group. The Class 1 E electrical equipment A/C trains are operated in a continuous recirculation mode to maintain the ESF switchgear rooms, the battery rooms, and the DC switchboard rooms to a temperature of:::; 90°F (Ref. 1 ). With one Class 1 E electrical equipment A/C train inoperable, the system design includes recirculation fans that provide adequate area cooling for both trains of electrical equipment during normal and accident conditions.

APPLICABLE The design basis of the Class 1 E Electrical Equipment A/C System is to SAFETY ANALYSES maintain temperature in the Class 1 E electrical equipment rooms to assure OPERABILITY of associated electrical equipment. The Class 1 E Electrical Equipment A/C System is designed so that the single failure of an active component coincident with a design basis accident (OBA) cannot impair the ability of the supported systems powered by the electrical equipment to fulfill their safety functions.

Wolf Creek - Unit 1 B 3.7.20-1 Revision XX

Attachment V to ET 17-0010 Page 3 of 6 Class 1 E Electrical Eq'uipment Air-Conditioning (A/C) System B 3.7.20 BASES APPLICABLE During normal operations each Class 1 E electrical equipment A/C train SAFETY A~ALYSES maintains the temperature in its.associated electrical equipment rooms (continued) at a temperatures 90°F. The Class 1 E electrical equipment A/C trains are designed in accordance with Seismic Category I requirements.

LCO APPLICABILITY Wolf Creek - Unit 1 As confirmed by analysis, the capability of a single Class 1 E electrical equipment A/C train to maintain area temperatures s 90°F for bot.h trains of electrical equipment during normal conditions, with the implementation of mitigating actions, corresponds to that train's capability to maintain area temperature s 104 °F for both trains of electrical equipment during

-accident conditions.

The Class 1 E Electrical Equipment A/C System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Two independent Class 1 E electrical equipment A/C trains are required to be OPERABLE to ensure adequate cooling to their associated electrical equipment rooms during normal operation. Each Class 1 E electrical equipment A/C train is considered to be OPERABLE when the individual components necessary to maintain associated electrical equipment room temperatures within acceptable limits are OPERABLE. These components include the refrigeration compressors, heat exchangers, cooling coils, ESW or normal service water flow, fans and associated temperature control instrumentation. In addition, the Class 1 E electrical equipment A/C trains must be OPERABLE to the extent that air circulation can be maintained.

In MODES 1, 2, 3, and 4, the Class 1 E Electrical Equipment A/C System is a normally operating system with both trains in operation. Both trains must be OPERABLE to ensure that the temperature in the protected rooms will not exceed equipment design limits.

Although the LCO for the Class 1 E Electrical Equipment A/C System is not applicable in MODES 5 and 6, the capability of the Class 1 E Electrical Equipment A/C System to perform its necessary related support functions may be required for OPERABILITY of supported systems.

B 3.7.20-2 Revision XX

Attachment V to ET 17-0010 Page 4of6 Class 1 E Electrical Equipment Air-Conditioning (A/C) System B 3.7.20 BASES ACTIONS Wolf Creek - Unit 1 A.1. A.2, and A.3 With one Class 1 E electrical equipment A/C train inoperable, action must be initiated immediately to implement mitigating actions. The mitigating action taken with one Class 1 E electrical equipment A/C train inoperable include starting the appropriate single train recirculating fans (includes opening discharge damper), placing in service the spare battery chargers, and one train of Control Building pressurization is secured within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if both trains are in operation. This mitigating action (i.e., action that is taken to offset the consequences of an inoperable Class 1 E electrical equipment A/C train) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.

A room area temperature limit of s 90°F is based on the normal operating maximum steady state environmental condition and a plant specific calculation for a single Class 1 E electrical equipment A/C train maintaining both Class 1 E electrical equipment train rooms at a temperature of s 104 °F during design basis accident conditions. The plant specific calculation envelopes affected room area temperatures being s 90°F at the onset of the design basis accident.

With one Class 1 E electrical equipment A/C train inoperable, the overall reliability of the cooling function is reduced. The remaining OPERABLE train can provide the required cooling function if mitigating actions are taken. The specified mitigating actions assume that the OPERABLE Class 1 E electrical equipment A/C train is capable of operating at full capacity. As demonstrated by analysis, the capability of a single Class 1 E electrical equipment A/C train to maintain area temperatures s 90°F for both trains of electrical equipment during normal conditions, with the mitigating actions implemented, corresponds to that train's capability to maintain area temperatures s 104 °F for both trains of electrical equipment during accident conditions.

Verifying the room area temperatures within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter is adequate to ensure temperatures remain belows 90°F. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable based on the minimal increase in room temperatures during this time period.

B 3.7.20-3 Revision XX

Attachment V to ET 17-001 O Page 5of6 Class 1 E Electrical Equipment Air-Conditioning (A/C) System B 3.7.20 BASES ACTIONS SURVEILLANCE REQUIRMENTS Wolf Creek - Unit 1 A.1, A.2. and A.3 (continued)

The Class 1 E electrical equipment A/C train must be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on the low probability of an event occurring during this time period and the capability of the remaining OPERABLE Class 1 E electric equipment A/C train to provide adequate area cooling for both trains of electrical equipment (with mitigating actions implemented).

If the room area tempe'ratures are not within limits when verified once per

~ hours, or if the inoperable Class fE electrical equipment A/C train cannot be restored to OPERABLE status within 30 days, Condition B must be entered.

B.1 and B.2 When the Required Actions of Condition A cannot be completed within the required Completion Times, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without.challenging unit systems.

If both Class 1 E electrical equipment A/C trains are inoperable in MODE 1, 2, 3 or 4, the Class 1 E Electrical Equipment A/C System may not be capable of performing its intended function. Therefore, LCO 3.0.3 must be entered immediately.

SR 3.7.20.1 This SR verifies that each Class 1 E electrical equipment A/C train starts

.and operates on an actual or simulated actuation signal. The actuation signals include the control room ventilation isolation signal (CRVIS) and actuations driven by the LOCA and shutdown sequencers. A CRVIS is generated by the inputs discussed in the LCO Bases for TS 3.3.7, "CREVS Actuation Instrumentation." The Frequencyof 18 months is based on industry operating experience and is consistent with the typical refueling cycle.

. *~::' ;

)

.. \\,*...

8 3.7.20-4 Revision XX

.)'

'}

Attachment V to ET 16-0033 Page 6of6 Class 1_E Electrical Equipment Air-Conditioning (A/C) System B 3.7.20 BASES SURVEILLANCE REQUIRMENTS (continued)

REFERENCES Wolf Creek - Unit 1 SR 3.7.20.2 Testing of the Class 1 E Electrical Equipment Air Conditioning (A/C)

System condenser heat exchangers under design conditions is impractical. This SR verifies that the heat removal capability of the air conditioning units is adequate to remove the heat load assun:ied in the control room during design basis accidents. This SR consists of verifying the heat removal capability of the condenser heat exchanger (either through performance t~sting or inspection), ensuring the proper operation of major: components in the refrigeration cycle, verification of unit air flow capacity, and water flow measurement: This SR is performed in the same manner as SR 3. 7.11.1 (Reference 2). The 18 month Frequency is appropriate since significant degradation of the Class 1 E Electrical Equipment.A/C System is slow and is not expected over this time period.

1.

USAR, Section 9.4.1.

2.

Letter from C.F. Lyon, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station - Interpretation of Technical Specification Surveillance Requirement 3.7.11.1, "Verify each CRACS train has the capability to remove the assumed heat load" (TAC NO. MF3665)," May 28, 2014.

B 3.7.20-5 Revision XX

Atta.chment VI to ET 17-0010 Page 1 of 1

{

LIST OF REGULATORY COMMITMENTS

\\

r The following tap[e,*.*identifies those actions committed to by Wolf Creek Nuclear Operating Corporation in '.this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments~. Please direct 1 questions regarding these commitments to Cynthia Hafenstine at (620) 364-420.4.

Regulatory Commitment j

Planned modifications are in process to achieve the capability for one Class 1 E electrical equipment A/C train to__provide

..i J

..... ~

adequate cooling for*both trains of electrical equipment during normal and accident conditions by design changes. The planned modifications include the following:

Computer points are used to verify the DC switchboard rooms and ESF switchgear room temperatures are less than 87°F and provide an alarm on the main control board. The temperature limits established for these rooms is ::; 90°F (this includes an allowance for instrument error of +/-3°F). The alarm setpoint on the associated temp~rature indicators will be lowered to 83°F.

2016' Level Installation of two recirculation fans (with control dampers) and 10 wall penetrations (with fire dampers) in the battery and switchboard rooms LED lighting in electrical equipment rooms 2000' Level Installation of four recirculation fans with control dampers in the ESF switchgear rooms LED lighting in electrical equipment rooms Due* Date It is anticipated that the planned modifications will be completed during the Spring 2018 Refueling Outage

v t e Letter Sequence Request
CAC:MF9961, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Open)
Initiation Request, Request Acceptance Supplement Administration Questions 6 April 2018 Answers Results Approval... Other: ML17291A008, ML18073A089
MONTHYEAR2018-02-15 [Table View]

ET 17-0010, License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C)System

Text

Reference:

Subject:

Subject:

SUMMARY

System Description

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

System Description

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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