ML20059K955

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Describes Plans & Schedule Developed for Implementation of Certain Improvements to Tech Specs Contained in App a to Facility Operating License & Request Commitment of NRC Staff Effort to Perform Review of Improvements
ML20059K955
Person / Time
Site: Wolf Creek 
Issue date: 01/26/1994
From: Hagan R
WOLF CREEK NUCLEAR OPERATING CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NA-94-0014, NA-94-14, NUDOCS 9402020387
Download: ML20059K955 (3)


Text

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i i-LF CREEK W@) NUCLEAR OPERATING Robert C. Hagan v.ce Prmk,mdeau Anunence jggg3py 26, jgg4 NA 94-0014 U.

S.

Nuclear Regulatory Commission ATTNt Document Control Desk Mail Station P1-137 Washington, D.C.

20555

Reference:

Final Policy Scatement on Technical Specifications Improvements for Nuclear Power Reactors, 58 FR 39132, July 22, 1993

Subject:

Docket No. 50-482:

Technical Specification Improvement Program Gentlemen:

The purpose of this letter in to describe the plans ' and schedule that Wolf Creek Nuclear Operating Corporation (WCNOC) has developed for-the implementation of certain improvements to the Technical-Specifications contained in Appendix A to the Wolf Creek Generating Station'a' (WCGS) operating license and to request the commitment of NRC staff effort to perform the review of these improvements.

This Technical specification Improvement Program (TSIP) is being undertaken as a joint effort with Union Electric, and will generally apply to the Technical Specifications 'for the Callaway Plant.

Preparing a joint license amendment will result in a significant savings in NRC staff review effort because the amendment requests for the two plants will be essentially identical.

This approach will also result in a savings of utility effort.

This letter is submitted as. requested during a meeting on December 8, 1993 between Mr.

C.

Grimes, et al. (NRC), Mr.

S.

Wideman - (WCNOC),

and Mr.

D.

Shafer (UE).

Publication of the referenced Policy Statement by the NRC has prompted WCNOC to consider the improvements in scope and content of Technical Specifications that may be realized through a combination of (1) application of the approved criteria for defining the scope of Technical Specifications, and (2) implementation of line item improvements to - Technical-' specifications.

Conversion to the improved Standard Technical Specifications (STS),

as encouraged by the Policy Statement, was considered but not adopted because of the high cost involved.

The course of action discussed in this letter was determined to be the most cost effective way to realize the safety benefits of.

improving the Technical Specifications.

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PO Dox 411/ Burlington. KS 66839 / Phone: (316) 364-8831

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9402020387 940126 An tw opportunity empioy.r uer/sc/ vet PDR ADOCK 05000482 R P

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,NA 9440014.

Page 2 of 3 An action plan has been prepared to govern (1) the preparation of a_ license amendment request that will apply the guidelines and criteria of.the Final 1

Policy Statement to the Wolf Creek Technical Specifications. and' (2) the establishment of priorities and schedules for submitting amendment requests to implement line item improvements.

Submittal' of the former request -is i

scheduled for the second quarter of 1994.

The line item improvement requests will likely be submitted over several years beginning in June 1994;.however, r

the specific dates are yet to be determined.

Consideration will be given to' l

s coordinating the requests for line item improvements with other utilities to maximize the efficiency of utility and NRC efforts.

The.results of the application of the criteria in the Policy Statement will'be

j contained in a report commonly called a " split report" because it, among other.

~

things, identifies how requirements will be split between those..that remain.'in the Technical Specifications and those 'that will be relocated to. other documents or programs.

The split report will form the basis.of'the safety.

evaluation justifying the proposed Technical Specification' changes.

The justifications contained in the split report will consist of the results of.

applying the.four criteria contained in the Final' Policy Statement to each of the WCGS Technical Specification Limiting Conditions of operation in Section-3/4. ' The 'results - of -applying the' criteria will be documented on screening j

forms. :In addition, the report will document ' the results ~ of comparing. the -

WCGS _ Technical Specifications against the simproved Standard: Technical Specifications applicable. to Westinghouse Plants (NUREG-1431).

The._ report will.also identify the documents or programs that will' form the repository of t

requirements removed from the Technical Specifications as a result of applying.

the criteria.

The requested changes will be based on the application of NRC-approved criteria.

The requirements removed.from the Technica1' Specifications will be-added to the Wolf Creek Updated Safety Analysis Report ' (USAR) Chapter 16.

_ As '

such, changes thereto will receive written safety evaluations under 10CFR50.59.

A new Section 7.0.of the Technical Specifications will' contain the USAR Chapter 16 relocated requirements.

Revision of this new Section 7.0 as well as USAR Chapter 16 will be under utility control, subject to the a

provisions of 10CFR50.59.

The planned license amendment package to implement the results of applying the Policy Statement criteria will consist of:

1._A cover letter,

2. A safety evaluation, which will include the split report, a summary of the application ' of the Policy Statement criteria, ' and _ the completed screening forms that underlie any proposed Technical Specification' changes,
3. A Significant Hazards Consideration Determination, 4.

An Environmental Evaluation, and

5. Marked-up Technical Specification pages, f

I B

+

4 4.

---a

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.NA 94-0014 Page 3 of 3 WCNOC is undertaking the above described Technical Specification Improvement-Program as a cost-ef fective way of obtaining the safety benefits that result from focusing the WCOS Limiting Conditions for Operation on requirements that are consistent with 10 CFR 50.36 and that have a sound safety basis.

The NRC."

staff'n support.is requested in this effort.

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.

Very truly yours,

/

./

.obert C. Hagan Vice President Nuclear Assurance RC11/jra cc:

L.

J.

Callan (NRC), w/a G.

A.

Pick (NRC), w/a W. D. Reckley (NRC), w/a L. A.

Yandell (NRC), w/a

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y

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