ML20059F184
| ML20059F184 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/27/1993 |
| From: | Hagan R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20059F187 | List: |
| References | |
| NA-93-0185, NA-93-185, NUDOCS 9311040166 | |
| Download: ML20059F184 (11) | |
Text
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W8LF CREEK
' NUCLEAR OPERATING CORPORATION Rotert C. Hagan Vice President Nuclear Assurance October 27, 1993 NA 93-0185 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station F1-137 Washington, D.
C.
20555
Reference:
Letter NA 93-0186 from R. C. Hagan, WCNOC, to Document Control Desk, NRC
Subject:
Docket No. 50-482: Revision to Technical Specification 4.6.1.2.a Gentlemen:
This letter transmits an application for amendment to Facility Operating License No.
NPF-42 for Wolf Creek Generating Station (WCGS)
This license amendment request proposes a one time scheduler exemption to Technical Specification 4.6.1.2.a, that requires three Type A tests (Containment Integrated Leakage Rate Test) be performed at 40 f.10 month intervals during each 10-year service period.
This one time scheduler exemption would allow the third test of the first 10-year service period to be p.
- ormed during the eighth refueling outage at approximately a 54 month in:arval instead of the current maximum technical specification interval of 50 months.
This exempt bn would also allow the third test of the first 10-year service period to be p-
'd approximately 6'
months beyond the 10-year service period.
Attachment I provides a safety evaluation including a description of the-proposed change.
Attachment II provides a no significant hazards consideration determination and Attachment III provides an environmental.
impact determination.
The specific change to the technical specification proposed by this request is provided.in Attachment IV.
In accordance with 10 CFR-50.91, a _ copy of this application, with attachments, is being provided to the designated Kansas State Official.
This proposed revision to the WCGS technical specifications will. be fully implemented within 30 days'of formal Nuclear Regulatory Commission approval.
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RO Box 411/ Burlington, KS 66839 / Pnone. (316) 364-8831 An Equal opportunity Employer WF/HC/ VET
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9311040166 931027 7
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1.j NA 93-0185 Page 2 of 2-If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4553, or Mr.
Kevin. J.
Moles,. at extension 4565.
't Very truly yours, f
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J P bert-C. Hagan
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Vice President Nuclear Assurance si RCH/jra f
Attachments I-Change Description and Safety Evaluation II - No Significant Hazards Consideration Determination III - Environmental Impact Determination IV - Proposed Technical Specification Change cc G. W. Allen (KDHE), w/a J. L. Milhoan (NRC), w/a
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G. A.
Pick (NRC), w/a W.
D. Reckley (NRC), w/a 1
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t STATE OF KANSAS
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r Robert C. Hagan, of lawful age, being first duly sworn upon oath says that he i
is Vice President Nuclear Assurance of~ Wolf Creek Nuclear Operating Corporation; that he has read the foregoing ' document and knows the content-thereof; that he has executed that same for and on behalf of said Corporationi with full power and authority to do so; and that the facts therein stated are.
l true and correct to the best of his knowledge, information and belief.
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SUBSCRIBED and sworn to before me this J 7 dayof.[1/0/>v, 1993.
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' Attachment.I to NA 93-0185 3
Page 1 of-4
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SAFETY EVALUATION
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Attachment 'I to NA 93-0185 1
Page 2 of 4 j
Safety Evaluation f
Proposed Chance This amendment request is a one time scheduler exemption to Technical Specification Surveillance Requirement 4.6 1.2.a and its associated Bases, which requires three Type A tests (Containment Integrated Leakage i
Rate Test (ILRT)) be performed at 40 110 month intervals during each 10-year service period.
Technical Specification 4.6.1.2.a also requires that the thir d test of each set be conducted during the shutdown for the 10-year plant inservice inspections.
This one time scheduler exemption would allow the third test of the first 10-year service period to be performed during the eighth refueling outage at approximately a 54 month-I interval instead of the current maximum technical specification interval of 50 months.
This exemption would also allow the third test of the first 10-year service period to be performed approximately 6 months beyond the 10-year service period.
g_a_qjLground Type A tests are defined in Section II.F of 10 CFR 50, Appendix J, as those tests intended to measure the primary reactor containment overall integrated leakage rate at periodic int ervals.
The time required to perform the ILRTs necessitates that they be performed during refueling outages with the time int erval between ILRTs being roughly 40 months based on the performance of three such tests at approximately equal intervals during each 10-year service period.
Since refueling outagei do not necessarily occur coincident with this 40-month interval, Technical Specification 4.6.1.2.a specifies that a variation of 110 months (i.e.,
a 25 percent variation) is permissible to permit flexibility in scheduling the ILRTs.
The first and second ILRTs, of the set of three tests for the first 10-year service period for Wolf Creek Generating Station (WCGS), were conducted in October 1988 and September 1991, respectively..
This renresents testing intervals of 45 and 35 months from the. initial precperational ILRT performed in January 1985.
This would indicate that the third of the first set of three ILRTs should be performed during the seventh refueling outage, scheduled for September 1994 which will:be 36 months after the preceding test and within the first 10-year service period.
However, the result of this testing sequence would cause an additional ILRT to be. performed during the 10-year plant inservice inspections scheduled for the eighth refueling outage in order to comply with the requirements of 10 CFR 50, Appendix J, Section III.D.1(a) and Technical Specification Surveillance Requirement 4.6.1.2.a, which require the third test of each set be conducted when the plant is shutdown for the 10-year plant inservice inspections.
In order to prevent performing this fourth ILRT in the first 10-year service period, WCNOC is proposing that the third ILRT for the first 10-year service period be performed in conjunction with the 10-year plant inservice inspections during the eighth refueling outage, scheduled for Spring 1996.
Therefore, this one time scheduler exemption is needed to allow this test period interval to exceed the 40 110 month requirement and for the third test of the first 10-year service period to be performed
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' Attachment I to NA 93-0185 Page 3 of 4 approximately six months beyond the 10-year. service period.
An exemption to exceed the 10-year interval of 10 CFR 50, Appendix' J,Section III.D.1(a) is being submitted by the Reference.
Evaluation of Proposed Chance Data from previous ILRTs conducted at WCGS indicate that the majority of the leakage that is measured during an ILRT is from the containment penetrations and not from the containment barrier itself.
Since this exemption request does not alter the Type B and C tests (Local. Leakage-Rate Test (LLRT)) program, which measures penetration and valve leakage, assurance that containment integrity is maintained can'also be verified by the performance of the LLRTs.
In addition to the LLRT's indication of containment integrity, the data from the first and second ILRT illustrates that the "as-left" leakage rates. were' well below the limit-established for acceptance in 10 CFR 50, Appendix J,
and technical-specifications.
The allowable leakage rate, L,
is 0.2 wt..%/ day; l
a however, 10 CFR 50, Appendix J,
and technical specifications requires-3 that the leakage rate be less than 75 percent of this value. (0.15 wt.%/ day) to allow for deterioration in the leakage paths between tests.
The "as-left" leakage rates for the first two ILRTs were 0.112 and 0.070 wt.%/ day, respectively, which is well below the acceptance limit.
f This one time exemption to extend the ILRT interval 4 months beyond the maximum technical specification allowance and into the 2nd 10-year service period will not adversely impact plant safety. The schedule for t
performing the Type B and C LLRTs is not affected and the majority of leakage from the containment is through penetrations and isolation valves.
The leakage rates assumed by accident analyses are unchanged and past ILRTs have produced leakage rates well below,the maxinum allowed by Technical Specification and Appendix.J.
The purpose of the ILRT is to provide periodic verification by tests of the leak-tight integrity of the primary reactor containment, and systems and components i
which penetrate containment.
The test assures that leakage through the 1
containment, and systems and components penetrating containment.will not-i exceed allowable leakage rate values associated' with the conditions resulting from any loss-of-coolant accident.
The - additional 4 month period added to the interval since the-performance of the last ILRT l
would not adversely affect the containment-integrity in the event of a loss-of-coolant accident.
Based on the above discussions and the-no significant hatards consideration determination presented in Attachment II, the proposed j
change does not increase the probability of occurrence-or the' consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report; or create a possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report; or reduce the margin of safety as defined in the basis for any technical specification.
Therefore, the proposed change does not adversely affect-or endanger the j
health or safety of the general public or involve a significant safety 7
hazard.
Attachment I to NA 93-0185 Page 4 of 4 Additional Information i
I Letter NO 92-0001 submitted Licensee Event Report 91-020-01 concerning leakage past Containment Isolation Valves EFHV32 and EFHV34 that resulted in the "as-found" ILRT conducted in September 1991 exceeding the allowable leakage value.
In accordance with Technical Specification 4.6.1.2(b) and 10 CFR 50, Appendix J,
Section III A.6.(a),
a test schedule applicable to subsequent Type A tests was submitted with the licensee event report for review and approval by the Commission.
This test schedule proposed to continue performing ILRTs every other' refueling outage, as per the original test schedule, which would indicate that the next ILRT is required to be performed during the seventh refueling outage scheduled for September 1994 This schedule was approved by-the Commission in a letter dated May 4,
1992, from Suzanne C.
Black, NRC, to Bart D. Withers, WCNOC.
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t htrachment-II to NA 93-0185 Page.1 of 2
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'I ATTACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION
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Attachment II to NA 93-0185 Page 2 of 2 No Significant Hazards Consideration Determination This amendment request is a one time scheduler exemption to Technical Specification Surveillance Requirement 4.6.1.2.a and its associated Bases, that requires three Type A tests (Containment Integrated Leakage Rate Test) be performed at 40 210 month intervals during each 10-year service period. This one time scheduler exemption would allow the third test of the first 10-year service period to be performed during Refueling Outage 8 at approximately a 54 month interval instead of the current maximum technical specification interval of 50 months.
This exemption would also allow the third test of the first 10-year service period to be performed approximately 6 months beyond the 10-year service period.
The following sections discuss the proposed change under the three standards of 10 CFR 50.92.
Standard I
- Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated This exemption applies to the ILRT and does not affect the local leak rate testing of containment penetrations and isolation valves where the majority of the leakage occurs.
The allowable containment leakage used in the accident analysis for offsite doses, L is 0,2 wt.%/ day and for a,
conservatism the leakage is limited to 75% L to account for the a
possible degradation of containment leakage barriers between tests.
Based on the "as-left" leakage data for the past two ILRTs, the additional time period added to the testing interval would not adversely impact the containment leakage barriers to where degradation would cause leakage to exceed that assumed in the accident analysis, a
Standard II - Create the Possibility of a New or Different Kind of i
Accident from any Previously Evaluated There are no design changes being made that would create a new type of i
accident or malfunction and the method and manner of plant operation remain unchanged.
The change to the Surveillance Requirement is a one 1
time exemption to extend the surveillance interval for performance of the third ILRT.
Standard III - Involve a Significant Reduction in the Margin of Safety There are no changes being made to the safety limits or safety system settings : hat would adversely inpact plant safety.
The change is a one time exeniption to extend the time interval for performing a ILRT approximately 4 months beyond the current maximum interval.
This change does not reduce any technical specification margin of safety.
Based on the aLove discussions, it has been determined that the requested technical specification revision does not involve
.a significant increase in the probability or consequences of an accident 1
or other adverse condition over previous evaluations; or create the possibility of an new or different kind of accident or condition over previous evaluations; or involve a significant reduction in a margin of' safety.
The requested license amendment does not involve a significant hazards consideration.
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Attachment III'to NA 93-0185 Page 1 of 2
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ATTACHMENT III j
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Attachment III to NA 93-0185 Page 2.of 2 Environmental Impact Determination 10 CFR 51.22 (b) specifies the criteria for categorical exclusions from the requirement for a specific environmental assessment per 10 CFR 51.21.
This amendment request meets the criteria specified in 10' CFR 51.22 (c) (9) as specified below:
(1) the amendment involves no significant hazards consideration As demonstrated in Attachment II, the proposed change does not involve any significant hazards consideration.
(ii) there is no significant change in the types or significant increase in the amounts of any offluents that may be released offsite The proposed change does not involve a change to the. facility or operating procedures which would cause an increase in the amounts of effluents or create new types of effluents.
(iii) there is no significant increase in individual or cumulative occupational radiation exposure The proposed change does not create additional exposure to personnel' nor affect levels of radiation present.
Also, the proposed change does not result in any increase in individual or cumulative occupational radiation exposure.
A benefit of this one time exemption is to eliminate the need to perform an extra ILRT during the first 10-year service period, thus a. reduction in personnel radiation exposure is realized.
The elimination of setup and restoration of the extra ILRT provides a dose savings from the elimination of contamination,- the reduction of exposure for venting and draining, and from setup and restoration of the instrumentation during and after the test.
Based on the above it is concluded that there will be no impact on the
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environment resulting from this change and the change meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from-the requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission.
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