ML20081J463

Application for Amend to License NPF-42,revising TS Surveillance Requirement 4.6.2.1.d, Containment Spray Sys, Per GL 93-05

ML20081J463
Person / Time
Site:	Wolf Creek
Issue date:	03/21/1995
From:	Johannes R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20081J467	List: ML20081J463 ML20081J476
References
CO-95-0003, CO-95-3, GL-93-05, GL-93-5, NUDOCS 9503270301
Download: ML20081J463 (11)

Text

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W$LF CREEK NUCLEAR OPERATING CORPORATION Richard N. Johannes Chef Admemstrative Officer March 21, 1995 CO 95-0003 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 Specification Surveillance Requirement 4.6.2.1.d, " Containment Spray System" 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 revising Technical Specification Surveillance Requirement 4.6.2.1.d, " Containment Spray System," to change the surveillance interval .,

specified for the performance of an air or smoke flow test through the containment spray header from *at least once per 5 years" to *at least once per i 10 years." The proposed change to the surveillance interval is consistent with i Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce  ;

Surveillance Requirements for Testing During Power Operation," and NUREG-1366,  !

" Improvements to Technical Specifications Surveillance Requirements."

Currently, this surveillance requirement is scheduled to be performed during the.

eighth refueling outage which is scheduled to begin during the spring of 1996.

Therefore, it is being requested that this proposed license amendment request be approved prior to the eighth refueling outage in order to take full advantage of l recommendations of Generic Letter 93-05 and NUREG-1366.

Attachment I provides a description of the proposed change along with a Safety i Evaluation. Attachment II providen a No Significant Hazards Consideration Determination. Attachment III provides the Environmental Impact Determination. j The specific change to the technical specifications proposed by this request is  :

provided as 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 i formal Nuclear Regulatory Commission approval.

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Richard N. Johannes //

Chief Administrati# Officer i SUBSCRIBED and sworn to before me this N/' day of N M , 1995.

CAROLYN E. LONG,

$J N. g .I Notary Public .;

NotaryPublic.Stateof Kansas f

,uy Appt. Ernires /-r-ff Expiration Date /-5'-99 i

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Attcchment I to CO 95-0003 Page 1 of 3 ATTAC300DIT I SAFETY EVALUATION

Attechment I to CO 95-0003 Page 2 of 3 Safety Evaluation Eroposed change This license amendment request proposes revising Technical Specification Surveillance Requirement 4.6.2.1.d to change the surveillance interval specified for the performance of an air or smoke flow test through the containment spray header from *at least once per 5 years" to *at least once per 10 years." The proposed change to the surveillance interval is consistent with Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements or Testing During Power Operation," and NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements."

Evaluation Technical Specification Surveillance Requirement 4.6.2.1.d requires that each Containment Spray System be demonstrated operable at least once per 5 years by performing an air or smoke flow test through each spray header and verifying each spray nozzle is unobstructed. Wolf Creek Generating Station procedure STS MT-003, " Containment Spray Systems Air Flow Test," is utilized to satisfy this surveillance requirement.

The Containment Spray System consists of two separate trains of equal capacity, each independently capable of meeting system requirements. Each train includes a containment spray pump, spray header and nozzles, spray additive eductor, containment recirculation sump screens, containment spray isolation valve encapsulation tank, valves, and necessary piping, instrumentation, flushing connections, and controls. The nozzles, which are of the hollow cone design, are i not subject to clogging by particles less than 7/16 inch in size. Independent electrical power supplies are provided for equipment in each containment spray train. In addition, each train is provided with electrical power from separate emergency diesel generators in the event of a loss of offsite power. The Containment Spray System is actuated either manually from the control room or on coincidence of two sets out of four containment Hi-3 pressure signals.

In December 1992, the NRC issued NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements." Section 8.1 of NUREG-1366, ,

Containment Spray System (PWR)," states that the NRC recommends that the surveillance interval of the air or smoke flow test be extended to ten years.

Specifically, the NRC staff searched for problems involving the Containment Spray System that had been uncovered during the performance of this surveillance requirement. Only three cases were discovered and in all three cases the problem involved a construction error. Also, the NRC stated that the performance of this surveillance requirement gives no quantitative data on flowrates exiting the nozzles. It only verifies that there is flow, which, from the operating data, does not appear to be a problem. Therefore, the NRC recommended that this surveillance requirement interval be extended to every 10 years.

Attachment I to CO 95-0003 l Page 3 of 3 On September 27, 1993, the NRC issued Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation." In this generic letter the NRC transmitted guidance to assist licensees in preparing license amendment requests to implement the recommendations of NUREG-1366 as line-item technical specifications improvements.

This generic letter documented the fact that in 1991, Southern California Edison Company reported that a Containment Spray System air flow test for San Onofre Unit 1 indicated that several nozzles were blocked. An investigation concluded that seven nozzles were clogged with sodium silicate, a coating material that was applied to the carbon steel Containment Spray System piping in 1977. The air flow tests that were conducted in 1980, 1983, and 1988 obtained acceptable results. However, this event did not alter the recommendations by the NRC for an extension of the air flow test surveillance interval for plants with the more '

commonly used stainless steel piping system. Wolf Creek Generating Station utilizes stainless steel piping in the containment spray System; therefore, an event of the type described in Generic Letter 93-05 is not possible.

Two surveillance air flow tests have been successfully performed at Wolf Creek Generating Station. These flow tests clearly demonstrated that obstructions did not exist for any of the spray nozzles. Wolf Creek Nuclear Operating Corporation considers the findings and recommendations of Generic Letter 93-05 and NUREG-1366 with respect to the containment spray header air or smoke flow test to be compatible with plant operating experience at Wolf Creek Generating Station.

Based on the above discussions and the considerations 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 that any previously evaluated in the safety analysis report; or reduce the nargin 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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l Attcchment II to CO 95-0003 PacJe 1 of 3 i

A7?ACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

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Attachmsnt II to CO 95-0003 Page 2 oY 3 i

No Significant Hazards Consideration Determination This license amendment request proposes revising Technical Specification Surveillance Requirement 4.6.2.1.d to change the surveillance interval specified I

for the performance of an air or smoke flow test through the containment spray header from "at least once per 5 years" to "at least once per 10 years." The proposed change to the surveillance interval is consistent with Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements or Testing During Power Operation," and NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements."

Standard I - Involves a significant Increase in the Probability or Consequences ,

of an Accident Previously Evaluated I

The proposed reduced testing frequency of the Containment Spray System nozzles does not change the way the system is operated or the Containment Spray System's operability requirements. The proposed change to the surveillance frequency of i safety equipment has no impact on the probability of an accident occurrence nor can it create a new or different type of accident. NUREG-1366 concluded that the corrosion of stainless steel piping is negligliale during the extended surveillance interval. Since the Containment Spray System is maintained dry there is no additional mechanism that could cause blockage of the spray nozzles.

Thus, the nozzles in the containment Spray System will remain operable during the ten year surveillance interval to mitigate the consequence of an accident previously evaluated. No clogging or blockage of the nozzles in the Containment Spray System has been discovered during the performance of the five year surveillance tests. Therefore, the testing of the containment Spray Systems nozzles at the proposed reduced frequency will not increase the probability or  ;

consequences of an accident previously evaluated.

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Standard II - Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed reduced frequency testing of the Containment Spray System nozzles does not change the way the containment Spray System is operated. The reduced frequency of testing of the spray nozzles does not change plant operation or ,

system readiness. The reduced frequency testing of the Containment Spray System l nozzles does not generate any new accident precursors. Therefore, the i possibility of a new or different kind of accident from any accident previously evaluated is not created by the proposed changes in surveillance frequency of the j Containment Spray System nozzles. j l

Attachment II to CO 95-0003 Page 3 of 3 i

Standard III - Involve a Significant Reduction in the Margin of Safety Reduced testing of the Containment Spray System nozzles does not change the way the system is operated or the Containment Spray System's operability requirements. NUREG-1366 concluded that the corrosion of stainless steel piping l is negligible during the extended surveillance interval. Since the Containment Spray System is maintained dry there is no additional mechanism that could cause blockage of the containment Spray System nozzles. Thus, the proposed reduced testing frequency is adequate to ensure spray nozzle operability. The surveillance requirements do not affect the margin of safety in the operability

requirements of the Containment Spray System remains unaltered. The existing safety analysis remains bounding. Therefore no margins of safety are adversely affected by this proposed change.

Bas <ed on the above discussions it has been determined that the requested technical specifien; an revision does not involve a significant increase in the probability or consequences of an accident or other adverse condition over j previous i.vt.lua tions ; or create the possibility of a new or different kind of accident or condition over previous evaluation; 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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i Att chment III to CO 95-0003 PacJe 1 of 2 i

ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION 1

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l Attachment III to CO 95-0003 PacJe 2 of 2 i

t Environmental Impact Determination .

i 10 CFR 51.22(b) specifies the criteria for categorical exclusions from the requirements for a specific environmental assessment per 10 CFR 51.21. This i amendment request meets the criteria specified in 10 CFR 51.22 (c) (9) . The  !

specific criteria contained in this section are discussed below.

(i) the amendment involves no significant hazards consideration j As demonstrated in the No Significant Hazards Consideration Determination in  ;

Attachment II, the requested license amendment does not involve any significant i hazards consideration.

(ii) there is no significant change in the types or significant increase in the amounts of any effluents thac may be released offsite The requested license amendment involve no 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 ef fluents 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 involves no change to the facility and does not ,

involve any change in the manner of operation of any plant systems involving the I generation, collection or processing of radioactive materials or 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. l Based on the above it is concluded that there will be no impact on the j environment resulting from this change. The change meets the criteria specified i 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. .

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