ML20082B029

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Forwards Response to Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events. Schedular Commitments May Change Due to Denial of Response Time Extension
ML20082B029
Person / Time
Site: Wolf Creek 
Issue date: 11/15/1983
From: Koester G
KANSAS GAS & ELECTRIC CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
GL-83-28, KLMNRC-83-147, NUDOCS 8311180330
Download: ML20082B029 (5)


Text

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KANSAS GAS AND ElhCTRIC COMPANY THE ELECT 84sC COMPANY GLENN L MOESTER veta PasseM=v. =vetgae November 15, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555 KMLNRC 83-147 Re:

Docket No. STN 50-482 Ref:

1) SLNRC 83-051 dated 9/6/83, Extension of Time for Response to NRC Generic Letter 83-28
2) NRC letter from DGEisenhut to all Licensees of Operation Reactors, Applicants for Operating License, and Holders of Construction Permits, Roquired Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28) dated 7/12/83.

Subj: Response to Generic Letter 83-28

Dear Mr. Denton:

The SNUPPS Utilities submitted a request to the NRC, Reference 1), for a time extension from November 4,1983, to February 29, 1984, in order to provide a fully integrated response to Reference 2), NRC Generic Letter 83-28.

This request was submitted September 6, 1983, in accordance with the provisions set forth in the Reference 2) letter. However, on October 26, 1983, SNUPPS was informed by a phone call from NRC (Dr. G.

Edison) that the extension request was denied and that a response was due November 15, 1983. As a result, the information available at this time to address Reference 2) with regard to the Wolf Creek Generating Station is provided in the attachment to this letter.

The information provided in the attachment is primarily schedular in nature without the coordination, integration and technical material necessary to fully address the requirements set forth in Reference 2). Proper integration with INPO and Owners' Group activities cannot be ensured at this time.

Consequently, the schedular commitments contained in the attachment may change.

8311180330 831115 Yours very truly, PDR ADOCK 05000482 pp)

G GLK:bb Attach

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cc: JHolonich (2)

WSchum/ASmith 201 N. Market -Wichita, Kansas - Man Address: PO. Box 208 I WicMa, Kansas 67201 - Telephone: Area Code (316) 261-6451

OATH OF AFFIRMATION STATE OF YJNSAS

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COUNTY OF SEDGWICK)

I, Glenn L. Koester, of lawful age, being duly sworn upon oath, do depose, state and affirm that I am Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal, know the contents thereof, and that all statements contained therein are true.

KANSAS GAS AND ELECTRIC COMPANY ATTEST:

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'Glenn L. Koes'ter Vice President - Nuclear E. D. Prothro Assistant Secretary STATE OF KANSAS

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COUR OF SEDGWICK)

BE IT REMEMBERED, that on this 15th day of November, 1983

, before me, Evelyn L. Fry

,a Notary, personally appeared Glenn L. Koester, Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known to me and who executed t.he foregoing instrument, and he duly acknowledged the execution of the same for and on behalf of and as the act and deed of said corporation.

IN WITNESS WHEPEOF, I have hereunto set my hand and affixe3 my seal the

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My Commission expires August 15, 1984

I ATTACHMINT RESPONSE 'IO NRC GENERIC LEITER 83-28 1.1 POST TRIP REVIEW (PROGRAM DESCRIPTION AND PROCEDURE) ne plant staff at Wolf Creek is developing the criteria, responsibilities, authorities, qualifications, training, sources of plant information, methods and criteria for ccriparing the event information with known or expected plant behavior, and the criteria for determining the need for independent assessment of an event.

The above procedures, methods, and criteria are scheduled to be in place by fuel load. A report describing the program at iblf Creek is scheduled for completion by 2/29/84.

1.2 POST TRIP REVIEW - DATA AND INFORMATION CAPABILITY A report is scheduled to be prepared by 2/29/84 that describes the Wolf Creek data and information capability for unscheduled reactor shutdowns. H is report will include the capability for assessing sequence of events; the capability for assessing the time history of needed analog variables; the functioning of safety-related equipment, data and information needed to assess the cause of unscheduled reactor shutdowns; and any planned modifications to the existing data and information capability along with the implementation schedule.

2.1 EOUIPMENT CLASSIFICATION AND VENDOR INTERFACE (REACIDR TRIP SYSTEM COMPONENTS)

KG&E is identifying a list of all safety-related components whose functioning is required to trip the reactor. Eis list will be used to confirnt that these conponents are identified as safety-related on documents, procedures, and information handling systems in the plant. His effort is scheduled for completion by fuel load.

i Regarding the requirement to implement and maintain a continuing program to ensure thac vendor information is complete, current and controlled throughout the life of the plant, KG&E is addressing this through a combination of the Westinghouse and INPO NUTAC programs. We Westinghouse program is in place via the Technical Bulletin system. We INEO NUTAC program is scheduled to be finalized by 2/01/84.

l A report is scheduled to be prepared by 2/29/84 that will describe how the Westinghouse and INPO NUTAC programs will be utilized at Wolf Creek.

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Attachment Page 2 2.2 EQUIPMENT CIASSIFICATION AND VENDOR INTERFACE (PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS) 2.2.1.1 ne criteria for identifying components as safety-related within systems currently classified as safety-related will be supplied in a report scheduled for completion by 2/29/84.

2.2.1.2 A description of the information handling system used to identify safety-related components and the methods used for its development and validation is scheduled for empletion by 2/29/84.

2.2.1.3 h e process and procedures required by this item are scheduled to be in place by fuel load.

2.2.1.4 Management procedures required by this item are scheduled to be in place by fuel load.

2. 2.1. 5 Appropriate design verification and qualification testing has been specified for the procurement of safety-related components. Rese documents have been previously furnished to the NRC in response to the NUREG-0588 requirements (see SINRC 83-0015 dated 3/10/83).

2.2.1.6 2 1s information has also previously been provided to the NRC (see SINRC 83-0015 dated 3/10/83).

2.2.2 h e program for vendor interface required by this item is scheduled I

to be finalized in the INP3 NUTAC program by 2/01/84. A descrip-tion of how the NUTAC program will be utilized at iblf Creek will be included in a report scheduled for completion 2/29/84.

3.1 POST MAINTENANCE TESTING (REACIOR TRIP S~1 STEM COMPONENTS) 3.1.1 Technical Specifications required by this item will be approved by the NRC and in place prior to fuel load. S e test and maintenance procedures required by this are scheduled to be in place by fuel load.

3.1.2 KG&E is in the process of finalizing procedures and Technical Specifications prior to fuel load. nese efforts will ensure that the checking process required by this item is accomplished as described in 3.1.1.

3.1.3 An NRC Task Force on Plant Technical Specifications Surveillance Requirements has been recently chartered and represents the appro-priate forum for addressing this section.

KG&E is also actively involved in the Westinghouse Ovners' Group (WOG) Technical Specifi-cation Optimization Program (TOP). His involvement and interface with the NRC Task Force, as exemplified in Letter OG-103 dated 9/16/83 (WOG-NRC Task Force on Plant Technical Specifications),

will ensure that changes to the Technical Specifications are ade-quately addressed.

Attachment Page 3 3.2 POST MAINTENANCE TESTING (ALL GINER SAFETY-REIATED COMPONENTS) 3.2.1 Seme response as given for 3.1.1 3.2.2 Same response as given for 3.1.2.

3.2.3 Same response as given for 3.1.3.

4.1 RF1CIOR TRIP SYSTEM RELIABILITY (VENDOR REIATED MODIFICATIONS)

Reactor trip breaker modifications are scheduled to be implemented by fuel load.

4.2 RF)CIOR TRIP SYSTEM RELIABILITY (PREVENTIVE MAINTENANCE AND SURVEILIANCE PROGRAM FOR REACIOR TRIP BREAKERS)

The proventive maintenance and surveillance prograns to ensure reliable reactor trip breaker operation will be defined for the IE-416 (Wolf Creek) breakers in the Westinghouse Maintenance Manual. his manual will be issued to Westinghouse Owners shortly after completion of life-cycle testing under a WDG program.

Life-cycle testing is currently scheduled for c mpletion in June 1984.

4.3 R')CIOR TRIP SYSTEM RELIABILITY (AITIOMATIC ACTUATION OF SHUNT TRIP ATTACHMENT FOR WESTINGHOUSE AND B&W PIANTS)

Wiring modifications to meet this requirement are scheduled to be cmpleted by fuel load. He schedule for installation of the Class lE coil will be provided by 2/29/84. A report addressing the plant specific open items of the final SER on the WOG generic shunt trip design package will be sutnitted by 2/29/84.

4.4 REACIOR TRIP SYSTEM RELIABILITY (IMPROVEMENTS IN MAINTENANCE AND TEST PROCEDURES FOR B&W PLANTS)

Not applicable.

4.5 REACIOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING) 4.5.1 Procedures for the on-line functional testing of the reactor trip-system, including the independent testing of the diverse trip features are scheduled to be in place by fuel load.

4.5.2 he iblf Creek plant is designed for oa-line testability; therefore, this iten does not apply.

4.5.3.

H e intervals for on-line functional testing are being reviewed by the WOG. Final recomendations will be provided by the VOG and incorporated in the NRC approved Technical Specifications for iblf Creek where possible.

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