ML17291A008
| ML17291A008 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/23/2017 |
| From: | Balwant Singal Plant Licensing Branch IV |
| To: | Heflin A Wolf Creek |
| Singal B, NRR/DORL/LPL4-1 | |
| References | |
| CAC MF9961, EPID L-2017-LLA-0262 | |
| Download: ML17291A008 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 23, 2017 Mr. Adam C. Heflin President, Chief Executive Officer, and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839
SUBJECT:
WOLF CREEK GENERATING STATION - REGULATORY AUDIT PLAN FOR NOVEMBER 7-8, 2017, SITE AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO INCORPORATE NEW TECHNICAL SPECIFICATION 3.7.20 (CAC NO. MF9961; EPID L-2017-LLA-0262)
Dear Mr. Helfin:
By letter dated June 28, 2017 (Agencywide Documents Access and Management System Accession No. ML17186A082), Wolf Creek Nuclear Operating Corporation submitted a license amendment request to incorporate new Technical Specification (TS) 3.7.20, "Class 1E Electrical Equipment Air Conditioning (A/C) System," to Wolf Creek Generating Station (WCGS) TSs.
The U.S. Nuclear Regulatory Commission staff has determined the need for a regulatory audit to be conducted at WCGS site in support of the review of the proposed TS change. The regulatory audit will be conducted from November 7 to November 8, 2017. The Enclosure to this letter provides an audit plan in support of this audit.
If you have any questions, please contact me at 301-415-3016 or via e-mail at Balwant.Sinqal@nrc.gov.
Sincerely,
~-tt-&1~
Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482
Enclosure:
Regulatory Audit Plan cc w/encl: Distribution via Listserv
REGULATORY AUDIT PLAN FOR NOVEMBER 7-8, 2017 AUDIT AT WOLF CREEK NUCLEAR GENERATING STATION TO SUPPORT REVIEW OF THE LICENSE AMENDMENT REQUEST TO INCORPORATE NEW TECHNICAL SPECIFICATION 3.7.20 DOCKET NOS. 50-482
1.0 BACKGROUND
By application dated June 28, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17186A082), Wolf Creek Nuclear Operating Corporation (WCNOC, the licensee), submitted a license amendment request (LAR) requesting for approval of a new Technical Specification (TS} related to room cooling for essential electrical equipment for Wolf Creek Generating Station (WCGS).
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 (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.
The U.S. Nuclear Regulatory Commission (NRG) staff is performing a detailed review of the proposed new TS. Due to the complexity of the proposed new TS, supporting calculations, proposed mitigating actions, and computer based modeling, the staff has determined that face-to-face interactions at the WCGS site can resolve complex technical issues more quickly than several rounds of request for additional information (RAI). Face-to-face interactions will also allow the staff to review and assess physical aspects of the LAR at the site through field walkdowns.
The NRC staff has determined the need for a regulatory audit to be conducted in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195), for the NRG staff to gain a better understanding of the licensee's calculations and other aspects of the LAR.
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain understanding, to verify information and/or to identify information that will require docketing to support the basis for the licensing or regulatory decision.
Enclosure
NRC Regulatory Requirements The regulatory bases for the audit are described in WCGS Updated Final Safety Analysis Report (UFSAR) (ADAMS Accession No. ML17151A982). Components comply with Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants" (as stated in UFSAR Sections 3.1.3, 3.1.4, 3.1.5, and 3.1.6).
Criterion 2 - "Design Bases For Protection against Natural Phenomena" Criterion 4 - "Environmental and Missile Design Bases" Criterion 13 - "Instrumentation and Control" Criterion 17 - "Electric Power Systems" Criterion 18 - "Inspection and Testing of Electric Power Systems" Criterion 20 - "Protection System Functions" Criterion 21 - "Protection System Reliability and Testability" Criterion 22 - "Protection System Independence" Criterion 23 - "Protection System Failure Modes" Criterion 24 - "Separation of Protection and Control Systems" Criterion 25 - "Protection System Requirements for Reactivity Control Malfunctions" Criterion 29 - "Protection against Anticipated Operational Occurrences" Criterion 44 - "Cooling Water" Additional requirements are as follows:
Paragraph 50.36(c)(3), "Surveillance requirements," of 10 CFR, states that TSs include SRs "relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."
Section 50.2 of 10 CFR definition "Design bases means that information which identifies the specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted "state of the art" practices for achieving functional goals, or (2) requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals."
Appendix A to 10 CFR Part 50, defines single failure as an "occurrence which results in the loss of capability of a component to perform its intended safety functions. Multiple failures resulting from a single occurrence are considered to be a single failure. Fluid and electric systems are considered to be designed against an assumed single failure if neither (1) a single failure of any active component (assuming passive components function properly) nor (2) a single failure of a passive component (assuming active components function properly), results in a loss of the capability of the system to perform its safety functions."
NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," Revision 4.0 (ADAMS Accession No. ML 121 OOA222), Section 1.1, defines "Operable-Operability" as follows:
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).
In order to be considered operable, structures, systems, or components (SSCs) must be capable of performing the safety functions specified by its design, within the required range of design physical conditions, initiation times, and mission times. In addition, TS operability considerations require that SSCs meet all SRs (as specified in the SRs). An SSC that does not meet a SR must be declared inoperable. In order to be considered operable, the SSC must be able to perform its specified safety function for the duration that is credited in the accident analysis for the SSC to perform its specified safety function.
3.0 REGULATORY AUDIT SCOPE/METHODOLOGY The purpose of this confirmatory audit is to determine if the calculations performed by WC NOC for WCGS support the bases for the proposed new TSs. The areas of focus for the audit are the calculation methodologies, assumptions, and results used to reach conclusions for the proposed TS.
4.0 INFORMATION NECESSARY FOR THE REGULATORY AUDIT WCNOC is requested to provide two hard copy sets of the documents listed in the Reference section. Half-size drawings are acceptable.
WCNOC is requested to make accessible licensee personnel or contractors who are familiar with the design of WCGS 1E Electrical Equipment A/C System, calculations noted in the reference section, and GOTHIC model, to assist the NRC staff during the audit.
Additional information needs, identified during the audit, will be communicated to the designated point of contact.
5.0 TEAM ASSIGNMENTS/RESOURCE ESTIMATES The resource estimate for this audit visit is approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of direct audit effort. The NRC staff performing this audit will be:
Audit Team The NRC/NRR audit team onsite will consist of:
- Larry Wheeler, Audit Team Lead, Technical Reviewer, Division of Safety Systems (DSS)/Containment & Plant Systems Branch (SCPB)
- Gurcharan (Singh) Matharu, Technical Reviewer, Division of Engineering (DE)/Electrical Engineering Operating Reactor Branch (EEOB)
- Balwant Singal, Project Manager, Division of Operating Reactor Licensing (DORL)/Plant Licensing Branch IV The following additional NRC staff may support the audit from the NRC headquarters:
- Nageswara Karipineni, Technical Reviewer, DSS/SCPB
- Pete Snyder, Technical Reviewer, DSS/Technical Specifications Branch (STSB)
- John Hughey, Technical Reviewer, Division of Risk Assessment (DRA)/Operations and Human Factors Branch (APHB)
- Gursharan Singh, Technical Reviewer, DE/Instrumentation and Controls Branch (EICB) 6.0 LOGISTICS The audit will start at 10:00 a.m. on Tuesday, November 7, 2017, and will conclude on Wednesday, November 8, 2017. The estimated length of the audit is approximately 2 days. See Table 1 below for audit agenda.
WCNOC is requested to provide a conference room to accommodate up to three NRC onsite staff with a telephone that allows conference calling with staff at NRC headquarters.
Table 1: Audit Agenda Date Time Item Responsibility Tuesday Site access badging and
-8:30 a.m.-10:00 a.m. dosimetry and brief meeting WCNOC/NRC Nov. 7, 2017 with resident inspectors NRC(NRC Entrance meeting, requests bridge 10:00 a.m-10:30 a.m. introductions, discuss purpose line with NRC and objectives of audit headquarters)
Overview of LAR and proposed new TS. Overview of 10:30 a.m. -12:00 p.m. supporting calculations & WC NOC drawing 12:00 p.m. - 1:00 p.m. Lunch Walkdown of areas that are 1:00 p.m. - 4:00 p.m. related to the new TS (including NRC/WCNOC main control room).
4:00 p.m. - 5:00 p.m. Audit of calculations WCNOC/NRC Wednesday 8:30 a.m. -12:00 p.m. Audit of calculations WCNOC/NRC Nov. 8, 2017 12:00 p.m. -1:00 p.m. Lunch 1:00 p.m. -4:00 p.m. Audit of calculations NRC/WCNOC NRC audit summary with NRC (bridge 4:00 p.m. - 4:30 p.m.
headquarters management line) 4:30 p.m. - 5:00 p.m. NRC site exit** NRC Turn in dosimetry and site 5:00 p.m. - 5:30 p.m. badge and exit with senior WCNOC/NRC resident inspector
- Audit exit may be adjusted based on NRC staff progress.
7.0 DELIVERABLES At the conclusion of the audit, the NRC staff will conduct an exit briefing and provide a summary of audit results in each subject area defined in the audit scope. The NRC staff plans to prepare a regulatory audit summary within 90 days of the completion of the audit.
Once the team leaves the site, the audit of calculations may continue at NRC Headquarters to allow support staff time to review calculations and time to generate followup calls as required.
8.0 REFERENCES
WCNOC calculations (primary focus of audit) and drawings:
- 1. WCNOC Calculation No. GK-06-W, "SGK05A/B Class 1 E Electrical Equipment Rooms A/C Units, Single Unit Operation Capability."
- 2. WCNOC Calculation No. GK-M-016, "Wolf Creek Control Building Loss of Class 1 E A/C GOTHIC Room Heat Up Analysis With Installed Crosstie Fans and Louvers."
- 3. WCNOC Calculation No. GK-E-001.
- 4. Piping and Instrumentation Drawings (P&IDs) for various related systems including the Class 1E Electrical Equipment AC System and related chilled water and service water systems.
- 5. Physical arrangement drawings of the areas of the Class 1E Electrical Equipment AC System and associated areas of cooling.
- 6. Other supporting calculations (as determined by WCNOC and NRC staff).
ML17291A008 *Via e-mail OFFICE N RR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/SCPB/BC NAME BSingal PBlechman JDennig*
DATE 10/23//17 10/19/17 10/18 /17 OFFICE NRR/DE/EEOB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JQuichocho RPascarelli BSingal DATE 10/23/17 10/23/17 10/23/17