ML20064C002
| ML20064C002 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/24/1994 |
| From: | Hagan R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20064C006 | List: |
| References | |
| NA-94-0024, NA-94-24, NUDOCS 9403090112 | |
| Download: ML20064C002 (11) | |
Text
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WOLF CREEK
' NUCLEAR OPERATING CORPORATION i
Robert C. Hagan Vico Presxient Nuclear Assurance Obruary 24, 1994 NA 94-0024 U.
S.
Nuclear Regulatory Commission ATTU : Document Control Desk Mail Station Pl-137 Washington, D. C.
20555
Subject:
Docket No. 50-482: Revision to Technical Specification
3.9.4 Gentlemen
This letter transmits an application for amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS).
This license i
amendment request proposes revising Technical Specification 3.9.4,
" Containment Building Penetrations," to allow the use of temporary alternate closure methods for the emergency personnel escape lock and containment wall l
penetrations, during alterations of the core or movement of irradiated fuel within containment.
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 1
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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I l PO. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 9403090112 940224 An Equal opportunity Employer M T/Hc/ VET PDR ADOCK 05000482 P
i NA 94-0024 i
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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, 5
Very truly yours,
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fobert C. Hagan Vice President j
Nuclear Assurance
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Attachments I - Safety Evaluation
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II - No Significant Hazards Consideration Determination
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III - Environmental Impact Determination
- i IV - Proposed Technical Specification Change i
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G.
W. Allen (KDHE), w/a i
L. J. Callan (NRC), w/a j
G. A.
Pick (NRC), w/a W. D. Reckley (NRC), w/a j-L. A. Yandell (NRC), w/a
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I STATE OF KANSAS
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SS COUNTY OF COFFEY
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Robert C. Hagan, of lawful age, being first duly sworn upon oath says that he 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 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.
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SUBSCRIBED and sworn to before me this 29# ' day of
'Mdy,1994.
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Expiration Date d /4,[95' l
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Attachment I to NA 94 0024 Page 1 og 4 ATTACIDfENT I SAFETY EVALUATION
4 Attachment I to NA 94-0024 I
Page 2 of 4 4
4 Safety Evaluation Pronosed Change This license amendment request proposes a revision to Technical Specification 3.9.4,
" Containment Building Penetrations," to allow the use of temporary alternate closure methods for the emergency personnel escape lock and containment wall penetrations during alterations of the core or movement of irradiated fuel within containment.
The specific revisions would add a note to Technical Specification
- 3. 9.4.b stating that "the emergency escape hatch l
temporary closure device is an acceptable replacement for the airlock door" and add the words "or approved functional equivalent" to Technical Specification 3.9.4.c.1.
Also, the Bases section for Technical Specification 3.9.4 would be revised to include a discussion on the use of equivalent i
isolation methods for the emergency personnel escape lock and containment wall i
Backaround Technical Specification 3.9.4 requires, in part, that a minimum of one door in each airlock be closed and that each penetration providing direct access from the containment atmosphere to the outside atmosphere be either closed by an isolation valve, blind flange, or manual valve, or be capaole of being closed by an operable automatic containment purge isolation valve.
These requirements are applicable during core alterations or movement of irradiated j
fuel within the containment.
Technical Specification 3.6.1.1 requires that primary containment integrity be maintained in Mode 1,
Power Operation, through Mode 4, Hot Shutdown.
During a refueling outage various activities must be completed inside containment, including sludge lancing and eddy current testing of the steam generators.
Sludge lancing of the steam generators is performed to remove sludge, which accumulates during power operation, from the tubesheet on the secondary side of the steam generators.
Eddy current testing is required by the plant's technical specifications to verify the integrity of the steam generator tubes.
Sludge lancing is currently accomplished by routing temporary hoses from an area outside of containment through the containment emergency personnel escape lock to the steam generators located inside containment.
However, f t'.Me performances of sludge lancing may include the routing of temporary hoses and cables through a containment wall penetration.
Sludge lancing must be performed during a time when there are no core alterations or mo verr ant of irradiated fuel within containment to ensure that the requirements of Technical Specification 3.9.4 are met since the emergency personnel escape lock must be open in order to allow the routing of the temporary hoses.
This requirement does not allow flexibility in the performance of the sludge lancing, since there are only short periods of time, during a typical refueling outage, in which the Technical Specifications will allow the containment to be open to the atmosphere.
Attachment I to NA 94-0024 Page 3 of 4 Eddy current testing requires the routing of cables from outside containment to the steam generators.
Due to the length of time required to complete eddy current testing, it commonly occurs during the periods when containment closure is required.
Therefore, temporary cables are routed through an existing containment wall penetration into containment and the penetration is sealed so that a direct access from the containment atmosphere to the outside atmosphere does not exist.
Prior to entering Mode 4,
the penetration is returned to its original condition and leak testing is performed to ensure that the requirements of 10 CFR Appendix J are met.
is being proposed that temporary hoses and/or cables be routed through the It containment penetrations (emergency personnel escape lock and/or containment wall penetrations) which would contain a temporary closure device containing equipment connections.
This would allow sludge lancing and eddy current testing activities to be accomplished during times when containment closure is required. This will simplify the scheduling of these activities and assist in reducing the length of refueling outages.
The temporary closure device and its equipment connections would meet the applicable design requirements for use during alterations of the core or movement of irradiated fuel within containment.
Installation and leak testing of the temporary closure device would also be controlled by plant procedures.
Evaluation During core alterations or movement of irradiated fuel assemblies within containment, a release of fission product radioactivity within the containment will be restricted from escaping to the environment, should a fuel handling accident occur, when the requirements of Technical Specification 3.9.4 are met.
In Mode 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere may be different than the requirements for Modes 1 through 4.
Technical Specification 3.9.4 Limiting Condition for Operation (LCO) requirements are referred to as " containment closure" rather than
" containment integrity" as specified in the LCO requirements for Technical Specification 3.6.1.1.
Containment closure means that all potential escape paths are closed (vapor-tight) or capable of being closed.
Since the results of an accident in which the potential for containment pressurization is not likely, the 10 CFR Appendix J leakage criteria and tests are not required.
Since the temporary closure device for the containment emergency personnel escape lock will be fabricated to the requirements for use during alterations of the core or movement of irradiated fuel within containment, and utilized, installed, and tested in accordance with plant procedures, the temporary closure device can be expected to perform in a manner equivalent to that of the emergency personnel escape lock door during a design basis event.
- Also, since either an emergency personnel escape lock door or the temporary closure device will be in place during core alterations or movement of irradiated fuel inside containment, current approved analysis concerning fuel handling accidents is still applicable.
Therefore, the ability of the containment building to ensure that any release of radioactive fission products will be restricted from escaping to the environment will remain unchanged by this proposed amendment.
Atta
- nt I to NA 94-0024 Page uf 4 The addition of the words "or approved functional equivalent" to Technical Specification 3.9.4.c.1 will clarify that a method other than the explicit use of isolation valves, blind flanges or manual valves are acceptable to ensure that containment closure is achieved during alterations of the core or i
movement of irradiated fuel within containment.
An equivalent isolation of a containment wall penetration, which provides direct access from the containment atmosphere to the outside atmosphere, will ensure that any release of fission product radioactivity within the containment will be restricted from escaping to the environment.
A properly installed temporary penetration seal will provide containment closure during refueling functionally equivalent to an isolation valve, blind flange or manual valve.
An engineering evaluation will be performed on each type of temporary seal used to meet the proposed Technical Specification 3.9.4.c.1 wording, to ensure that the seal is indeed equivalent for postulated accident scenarios during core alterations or movements of irradiated fuel in containment.
Also, the proposed wording of Technical Specification 3.9.4.c.1 is consistent with the wording contained in NUREG-1431, " Standard Technical Specification For Westinghouse Plants."
Based on the above discussions and the no significant hazards consideration determination presented in Attachment II, the proposed 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 I
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 health or safety of the general public or involve a significant safety hazard.
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. Attachment II to NA 94-0024 Page 1 of 2 i
ATTACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETETJ4INATION
. Attachment II to NA 94-0024 Page 2 of 2 No Significant Hazards Consideration Determination This license amendment request proposes a revision to Technical Specification 3.9.4,
" Containment Building Penetrations," to allow the use of temporary alternate closure methods for the emergency personnel escape lock and containment wall penetrations during alterations of the core or movement of irradiated fuel within the containment. Also, the Bases section for Technical Specification 3.9.4 would be revised to include a discussion on the use of equivalent isolation methods for the emergency personnel escape lock and containment wall penetrations.
Standard I - Involve a
Significant Increase in the Probability or Consequences of an Accident Previously Evaluated The probability of occurrence of a previously evaluated accident is not increased because failure to maintain containment closure is not an initiating condition for fuel handling accident.
The use of temporary alternate closure methods for the emergency personnel escape lock and containment wall penetrations does not introduce any new potential accident initiating condition during refueling operation.
The consequences of an accident previously evaluated is not increased because the use of temporary alternate closure methods for the emergency personnel escape lock and containment wall penetrations will provide the assurance of containment closure during refueling activities.
The ability of containment to restrict the release of any fission product radioactivity to the environment remains unchanged.
Standard II - Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The failure of the temporary alternate closure methods for the emergency personnel escape lock and containment wall penetrations during refueling will not result in a malfunction of any other plant equipment.
The sole purpose of establishing containment closure for refueling is to restrict the release of any fission product radioactivity in the event of a fuel handling accident.
Standard III - Involve a Significant Reduction in the Margin of Safety The temporary alternate closure methods for the emergency personnel escape lock and containment wall penetrations will provide the same assurance of containment closure during refueling for credible accident scenarios.
The ability of containment to restrict the release of any fission product radioactivity to the environment, should a fuel handling accident occur, j
remains unchanged.
Based on the above 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 or other adverse condition over j
previous evaluations; or create the possibility of a 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.
Attachment III to NA 94-0024 Page 1 of 2 1
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ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION 1
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.. Attachment III to NA 94-0024 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 l
i As demonstrated in Attachment I3, the proposed change does not involve any significant hazards consideration.
i (ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite The proposed change does rot involve a change to the f acility 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 l
affect levels of radiation present. Also, the proposed change does not result in any increase in individual or cumulative occupational radiation exposure.
Based on the above it is concluded that there will be no impact on the 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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