ML20079S154

Application for Amend to License NPF-42,revising TS SR 4.7.1.2.1.c.2 & 4.3.2.2

ML20079S154
Person / Time
Site:	Wolf Creek
Issue date:	10/21/1994
From:	Johannes R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20079S158	List: ML20079S154 ML20079S165
References
CO-94-0028, CO-94-28, NUDOCS 9410250258
Download: ML20079S154 (11)

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' NUCLEAR OPERATING CORPORATION Rchard N Johannes Ch.et Adourwtrat've Oncer October 21, 1994 CO 94-0028 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station F1-137 Washington, D. C. 20555

Subject:

Docket No. 50-482: Revision to Technical Specifications

- Auxiliary Feedwater System and Engineered Safety Features Actuation System Gentlemen:

This letter transmits an application for amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS), Unit No. 1. This license amendment request proposes revising Technical Specification Surveillance Requirements 4.7.3.2.1.c.2 [cperability testing for the turbine-driven auxiliary feedwater (AFW) pump auto start feature] and 4.3.2.2

[ engineered safety feature (ESF) actuation system instrumentation (ESF respense time testing for the turbine-driven AFW pump)] These specifications are being re. vised to indicate that the provisions of Technical Specification 4.0.4 are not applicable for entry into Mode 3. In addition, Technical Specification Surveillance Requirement 4.7.1.2.1.c has been revised to delete the requirement to be performed during shutdown.

These technical specification surveillance requirements are being revised to delete an administrative inconsistency due to the system limitations to supply steam to the turbine-driven AFW pump prior to entry into Mode 3. This inconsistency was identified by Northeast Nuclear Energy Company's Millstone Nuclear Power Station, Unit No. 3. Wolf Creek Nuclear Operating Corporation was notified by Millstone of this event and after review of the WCGS technical specifications, identified a similar situation.

This request involves no significant safety impact, and the operational risk associated with the request has no impact on public health and safety.

Attachment I provides a Safety Evaluation along with a detailed description of the proposed changes. Attachment II provides a Significant Hazards Consideration Determination. Attachment III provides an Environmental Impact Determination. The specific changes to Technical Specifications proposed by this request are provided as Attachment IV.

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CO 94-0028 Page 2 of 2 l

, In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Kansas State Official.

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l If you have any questions concerning this matter, please contact me at (316) 364-8831 extension 4001 or Mr. Richard D. Flannigan at extension 4500.

.; Very truly yours, I,

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'(} ,#Ml/Y/. c'f) '/J Nd D c D i

Richard N. Johanny/'

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t Attachments: I - Safety Evaluation II - No Significant Hazards Consideration Determination j III - Environmental Impact Determination IV - Proposed Technical Specification Change

! cc: G. W. Allen (KDHE), w/a l D. D. Chamberlain (NRC), w/a f L. J. Callan (NRC), w/a

) J. C. Stone (NRC), w/a

{ J. F. Ringwald (NRC), w/a f

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STATE OF KANSAS )

) SS COUNTY OF COFFEY )

l Richard N, Johannes, of lawful age, being first duly sworn upon oath says that he is Chief Administrative Officer of Wolf Creek Nuclear Operating l 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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BY #

LIND A M. OHMIE Richard N. Johannes j9 Notary Pubhc State of Kansas l , He Appt Empires 3-3\ * \gy Chief AdministrativeA fficer SUBSCRIBED and sworn to before me this f day of , 1994.

e 'nch R.Onmov Notary Public Expiration Date bk' l

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Attachment I to CO 94-0028 Page 1 of 3 Attachment I Safety Evaluation

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Attachment I to CO 94-0028 Page 2 of 3 Safety Evaluation Hackground 1 The Auxiliary Feedwater (AFW) system supplies feedwater to the steam generator to remove decay heat from the reactor coolant system upon the loss of normal feedwater supply. Wolf Creek Generating Station (WCGS) has two motor-driven AFW pumps and one turbine-driven AFW pump.

To ensure that the turbine-driven AFW pump is capable of fulfilling its safety I function, the WCGS Technical Specifications require that the operability of  ;

the pump be demonstrated. Specifically, Surveillance Requirement 4.7.1.2.1.c.2 ensures that the turbine-driven AFW pump will start automatically in the event of an accident or transient that generates an AFW actuation signal. This surveillance is performed on an 18-month shutdown frequency. In addition, Surveillance requirement 4.7.1.2.1.a.2 requires l hydraulic testing of the turbine-driven pump on a quarterly basis.

Surveillance Requirement 4.7.1.2.1.a.2 includes an exemption from the l provision of Technical Specification 4.0.4 for entry into mode 3. Technical i

Specification 4.0.4 states, " Entry into an OPERATIONAL MODE or other specified l condition shall not be made unless the Surveillance Requirement (s) associated with a Limiting Condition of Operation has been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with l ACTION requirements." This exemption allows proper testing conditions for the

! turbine-driven AFW pump. It is necessary to have adequate steam pressure I available so as not to damage the pump and to ensure validity of the surveillance. However, Surveillance Requirement 4.7.1.2.1.c.2 does not have a similar provision. This appears to have been an administrative oversight. A similar condition exists relative to surveillance Requirement 4.3.2.2. as it  !

relates to the turbine-driven AFW pump testing to support Engineered Safety Features (ESF) response time testing. Therefore, a modification to l Surveillance Requirement 4.3.2.2 is also required.

l WCGS has performed the Surveillance Requirement 4.7.1.2.1.c.2. However, this test has not been consistently performed during shutdown conditions and has j typically been performed during power operations to ensure proper steam conditions. Although WCGS has not complied verbatim with the surveillance requirements, WCGS has demonstrated the Turbine-driven AFW pump to be operable. This test was last performed in January 1994. No work to the turbine-driven AFW circuitry has been performed during the seventh refueling outage.

PIspnand Change Wolf Creek Nuclear Operating Corporation (WCNOC) is proposing to modify I

surveillance requirement 4.3.2.2 and 4.7.1.2.1.c.2 by adding an exemption from surveillance requirement 4.0.4. This will allow the plant to enter Mode 3 to perform the operability tests for the turbine-driven AFW pump. Technical Specification 4.7.1.2.1.c.2 verifies that the turbine driven AFW pump starts as designed automatically upon receipt of an AFW actuation test signal. The existing surveillance requirement requires this testing to be performed during shutdown. However, suitable plant conditions are not available for performing this test during shutdown conditions.

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Attachment I to CO 94-0028 Page 3 of 3 Therefore, the shutdown requirement is also being deleted. Entry into Mode 3 is necessary so that sufficient steam pressure is available to perform the required tests. For example, although currently not the case at WCGS, if the turbine governor is reworked in Mode 5 to correct an overspeed trip condition, the pump must be retested to ensure that the turbine does not overspeed trip on autostart. However, as currently written, Surveillance requirement 4.7.1.2.1.c.2 does not allow an entry into Mode 3 to perform the retest. The proposed change will correct this situation. It is noted that the NRC Staff has recognized this situation and the correction to this is reflected in the new, improved Standard Technical Specifications for Westinghouse Plants l (NUREG-1431)

A similar condition exists relative to Surveillance Requirement 4.3.2.2 as it ,

relates to the turbine-driven AFW testing to support Engineered Safety Features (ESP) response time testing requirement. Therefore, it being proposed that a note is being added to indicate that requirements of Specification 4.0.4 are not applicable for entry into Mode 3 for AFW ESF response time testing. It is noted that the NRC Staff has recognized this situation and the correction to this is reflected in the new, improved Standard Technical Specifications for Westinghouse Plants (NUREG-1431).

The marked-up technical specification pages are provide in Attachment IV.

EnluAtion The proposed change to surveillance Requirement 4.3.2.2 and 4.7.1.2.1.c.2 will allow an exemption f rom the provisions of Specification 4.0.4 ior entry into Mode 3. The proposed change will also remove the shutdown equirement for surveillance 4.7.1.2.1.c.2. This will allow for appropriate ,est conditions for the turbine-driven AFW pump., These changes do not have any impact on the accidents previously evaluated. This situation is recognized in the Standard Technical Specifications for Westinghouse plants (NUREG-1431) where a similar exemption from the requirements of Technical Specification 4.0.4 appear and the shutdown requirement has been deleted. The proposed changes do not modify the surveillance acceptance criteria nor do they change the frequency of the surveillance. The proposed change only allows the proper plant conditions for testing. The proposed changes do not have any adverse impact on the design basis accident radiation dose calculations, because the proposed testing conditions or methods are not assumed in any dose calculations. Therefore, the proposed changes do not pose a condition adverse to safety, and there are no adverse safety consequences created by the proposed change.

Attachment II to CO 94-0028 Page 1 of 3 Attachment II No Significant Hazards Consideration Determination

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l Attachment II to CO 94-0028 I Page 2 of 3 l

No Significant Hazards Consideration Determination WCNOC has reviewed the proposed changes in accordance with 10 CFR 50.92 and concluded that the changes do not involve a significant hazards consideration.

The basis for this conclusion is that the three criteria of 10 CFR 50 92 (c) are satisfied. The proposed changes do not involve a significant hazards consideration because the changes would not:

Standard I - Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated WCNOC is proposing to modify Surveillance Requirements 4.3.2.2 and l 4.7.1.2.1.c.2 by adding an exemption for the provisions of Technical Specification 4.0.4 and deleting the shutdown requirement. Entry into Mode 3 would allow for appropriate test conditions (e.g., adequate steam pressure available) to complete the operability testing of the turbine-driven AFW pump.

The acceptance criteria such as response time, or test frequency, are not revised. Therefore, the surveillance will continue to verify the operability of the turbine-driven AFW pump. Additionally, the proposed changes are consistent with the new, improved Standard Technical Specifications for Westinghouse plants (NUREG 1431).

I Considering the above, the proposed changes to Surveillance Requirements l 4.3.2.2 and 4.7.1.2.1.c.2, of the WCGS Technical Specifications, do not involve a significant increase in the probability or consequences of an l l accident previously analyzed.

Standard II - Create the Possibility of a new or Different Kind of Accident from any Previously Evaluated.

The proposed changes do not make any physical or operational changes to existing plant structures, systems, or components. The proposed changes do not introduce any new failure modes. They simply allow tests to be performed at appropriate conditions rather than during shutdown.

Additionally, the proposed changes do not modify the acceptance criteria for the tests. The purpose of the tests is to ensure that the turbine-driven AFW  !

pump can perform its intended function.

Thus, the proposed changes do not create the possibility of a new or different kind of accident from any previously analyzed.

Standard III - Involve a Significant Reduction in the Margin of Safety The proposed changes do nt have any adverse impact on the Updated Safety Analysis Report accident analyses. The applicable acceptance criteria for the turbine-driven AFW pump will not be modified by these proposed changes. The proposed changes will permit the tests to be conducted under the proper conditions, so that the ability of the turbine-driven AFW pump to perform its intended safety function can be confirmed.

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Attachment II to CO 94-0028

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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 conditions; or involve a significant reduction in the margin of safety.

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Attachment III to CO 94-0028 Page 1 of 2 l

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I Attachment III l

Environmental Impact Determination t

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Attachment III to CO 94-0028 Page 2 of 2 Environmental Impact Determination 10 CFR 51.22 (b) specifies the criteria for categorical exclusions from the requirements for a specific environment,'l assessment per 10 CFR 51.22 (c) (9).

The specific criteria contained in this section are discussed below.

(i) the mmendment involves no significant hazards consideration As demonstrated in the No Significant Hazards Consideration Determination in Attachment II, the requested license amendment does not involve any significant hazards consideration.

(ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite The requested license amendment does not involve a change to the facility and does not involve any change in the manner of operation of any plant systems involving the generation, collection or processing of radioactive materials or other types of effluents. Therefore, no increase in the amounts of eft;uents or new types of effluents would be created.

(iii) there is no significant increase in individual or cumulative occupational radiation exposure The requested license amendment does not involve a change to the facility and does not involve any change in the manner of operation of any plant systems i involving the generation, collection or processing of radioactive materials or l other types of effluents. Furthermore, implementation of this proposed change will not involve work activities which could contribute to occupational radiation exposure. Therefore, there will be no increase in individual or cumulative occupational radiation exposure associated with this proposed change.

Based on the above discussion it is concluded that there will be no impact on l the environment resulting from this change. 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 specific environmental assessment by the Commission, l

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