ML20086T396
| ML20086T396 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/28/1995 |
| From: | Hagan R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ET-95-0079, ET-95-79, NUDOCS 9508030011 | |
| Download: ML20086T396 (16) | |
Text
_
e W$LF CREEK NUCLEAR OPERATING CORPORATION Robert C. Hagan Vice President Eng noenng July 28,1995 ET 95-0079 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555
Reference:
Letter ET 95-0078, dated July 28, 1995, from R.
C.
Hagan, WCNOC, to the NRC
Subject:
Docket No. 50-482:
Exigent Change to License Condition 2.C (1), Attachment 1, to Operating License No. NPF 42 Gentlemen:
This letter transmits an exigent change to License Condition
- 2. C (1),
Attachment 1,
to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS)..
Wolf Creek Nuclear Operating Corporation (WCNOC) requests that this Operating License change be reviewed under the exigent circumstances provisions of 10 CFR 50. 91(a) (6).
This proposed change to the Operating License would delete License condition 2.C(1), which required that the emergency diesel generator lube oil keepwarm pumps for WCGS be replaced with ones satisfying ASME Section III, Class 3, requirements prior to startup j
following the first refueling outage. On July 27, 1995, the ASME Section III, Class 3,
keepwarm pump for emergency diesel generator "A"
failed and a qualified ASME Code replacement pump is unavailable.
Therefore, a non-ASME Section III, Class 3, replacement pump would have to be installed, which would be contrary to the operating License Condition.
The Reference transmitted a request that the NRC exercise enforcement discretion regarding compliance with License Condition 2.C(1), Attachment 1,
a until this exigent Operating License Change is considered for approval by the NRC staff.
The Reference was verbally discussed with the Office of Nuclear Reactor Regulation and the NRC Region IV Office on July 28,
- 1995, and l
subsequently verbally approved.
I 9500030011 950728 g
PDR ADOCK 05000482 P
PDR i Lg{
OEO Og Ro. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 d
An Equal Opponunny Employer MT/HC/ VET
t ET 95-0079 Page 2 of 2 Attachment I provides a detailed Safety Evaluation including a description of the proposed change and a detailed discussion on the exigent nature of the requested change.
Attachment II provides a
No Significant Hazards Consideration Determination and Attachment III provides an Environmental Impact Determination. A marked-up page indicating the deletion of the License Condition 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.
If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4553, or Mr.
Richard D.
Flannigan, at extension 4500.
Very truly yours, l
l m
Robert C. Hagan RCH/jra Attachments I
- Safety Evaluation II - No Significant Hazards Consideration Determination III - Environmental Impact Determination IV - Proposed Technical Specification Changes cc:
G.
W.
Allen (KDHE), w/a L.
J.
Callan (NRC), w/a D.
F.
Kirsch (NRC), w/a J.
F.
Ringwald (NRC), w/a J.
C.
Stone (NRC), w/a
STATE OF KANSAS
)
)
SS COUNTY OF COFFEY
)
Robert C. Hagan, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering 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.
ANGELA E.WESSEL
,Y / [
Notary Public. State of Kansas Hagan f,
V$ pert C.
o 4 t/v Ap*>t. Erpires 9ble3, /99'l ce President Engineering SUBSCRIBED and sworn to before me this A6 day of
@, 1995.
h w.is.> A. & 1 d Notary P4blic i
Expiration Dr.Le
$n s u. 3 /999 a-(
l e
Attachment I to ET 95-0079 I
Page 1 of 6 l
i ATTACHMENT I SAFETY EVALUATION
Attachment I to ET 95-0079 Page 2 of 6 Safety Evaluation Proposed Changg This exigent change proposes to delete License Condition 2.C(1), Attachment 1, contained in Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS).
This License condition required that the emergency diesel generator lube oil keepwarm pumps for WCGS be replaced with ones satisfying ASME Section III, Class 3,
requirements prior to startup following the first refueling outage.
On July 27, 1995, the ASME Section III, Class 3,
keepwarm pump for emergency diesel generator "A"
failed and a qua3Afied ASME Code replacement pump is unavailable. No replacement parts are currently available to repair the failed pump.
Background
on July 27, 1995, the lube oil keepwarm pump for emergency diesel generator "Aa failed.
The lube oil keepwarm pump operates continuously while the diesel engine is in a standby mode of operation.
Following the failure of the keepwarm pump, emergency diesel generator "A"
was declared inoperable and Technical Specification 3.8.1.1, Action b,
was entered.
This technical specification requires, in part, that the inoperable emergency diesel generator be returned to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit must be placed in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
The emergency diesel generator was declared inoperable since the lube oil keepwarm pump was unavailable to circulate the oil within the keepwarm system.
The oil must be circulated in order to maintain the oil in the emergency diesel generator sump in a warm condition to ensure a quick start of the engine.
Also, the keepwarm pump was unavailable to prelubricate the essential engine components and to maintain oil purity by continuous filtration.
On July 28, 1995, the mechanical overspeed trip device on the "B"
emergency diesel generator actuated due to a possible governor adjustment problem and the diesel generator was declared inoperable and Technical Specification 3.8.1.1, Action f,
was entered.
This technical specification requires, in part, that one of the two inoperable emergency diesel generators be returned to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the unit must be placed in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Subsequently, the "A" emergency diesel generator was started and rtu until the lube oil temperature was returned to within the required temperature band.
The "A"
emergency diesel generator was then declared operable with the ASME Section III class 3 keepwarm pump isolated.
WCNOC remains in Technical Specification 3.8.1.1, Action b, due to the inoperable "B"
emergency diesel generator. WCNOC will continue to periodi': ally start the "A" emergency diesel generator until a non-ASME Section I1I, Class 3,
replacement pump can be installed or until the "B"
emergency diesel generator governor is repaired and the engine is returned to operable status.
Attachment I to ET 95-0079 Page 3 of 6 Previous attempts to obtain an ASME Section III, Class 3, replacement pump or parts have been unsuccessful.
Crane Deming, the original manufacture of the pump no longer produces the pump and a qualified ASME Code replacement is unavailable.
A non-ASME Section III, Class 3 replacement keepwarm pump will have to be installed which will be in violation of License Condition 2.C(1),
Attachment 1.
Therefore, a request to exercise enforcement discretion was initiated to permit the installation of the keepwarm pump until this exigent License Condition change can be considered for approval by the NRC.
The deletion of the License Condition is based on the fact that the application that the pumps are utilized in, does not have to satisfy the requirements of ASME Section III, Class 3.
Determination of the Exigent Basis of the Proposed Change On July 27, 1995, emergency diesel generator "A"
was declared inoperable and Technical Specification 3.8.1.1, Action b,
was entered.
This technical specification requires, in part, that the inoperable emergency diesel generator be returned to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit must be placed in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
On July 28, 1995, the mechanical overspeed trip device on the "B"
emergency diesel generator actuated due to a possible governor adjustment problem. The diesel generator was declared inoperable and Technical Specification 3.8.1.1, Action f was entered.
This technical specification requires, in part, that one of the two inoperable emergency diesel generators be returned to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the unit must be placed in at least hot standby with in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Subsequently, the "A" emergency diesel generator was started and run until the lube oil temperature was returned to within the required temperature band.
The "A"
emergency diesel generator was then declared operable with the ASME Section III Class 3 keepwarm pump isolated.
WCNOC remains in Technical Specification 3.B.1.1, Action b, due to the inoperable "B"
emergency diesel
)
generator.
WCNOC will continue to periodically start the "A"
emergency diesel J
generator until a non-ASME Section III, Class 3,
replacement pump can be installed or until the "B" emergency diesel generator governor is repaired and the engine is returned to operable status.
To comply with the License condition of the Operating License would require the installation of an ASME Section III, Class 3,
replacement keepwarm pump.
However, since an ASME replacement pump is unavailable, an exigent change to the License Condition is needed in order to install a non-ASME pump.
For these reasons, WCNOC has determined that exigent circumstances, as defined in 10 CFR 50.91 (a) (5), exist for this proposed change and requests that NRC 2
review this request in a timely manner.
-7
i Attachment I to ET 95-0079 Page 4 of 6 Eyaluation The purpose of the lube oil keepwarm pump is to circulate lube oil through the emergency diesel generator while it is in the standby mode.
This provides pre-lubrication to the engine, maintains the lube oil at approximately 120 degrees Fahrenheit, and provides a continuous oil filtration path.
When the emergency diesel generator is in operation the engine driven lube oil pump circulates the lube oil through the engine and the keepwarm pump is not j
l required.
However, the keepwarm pump continues to operate providing a secondary filtration path to that provided by the engine drive pump.
The keepwarm pump performs no active safety-related function and must only maintain preasure boundary once the emergency diesel is in operation.
The emergency diesel generators were originally installed with non-ASME Section III, Class 3, lube oil keepwarm pumps which are similar in design to the replacement keepwarm pump WCGS is currently installing on the "A"
The non-ASME keepwarm pumps were replaced with keepwarm pumps meeting the ASME Section III Class 3 requirements prior to startup testing of the emergency diesel generators.
However, the ASME keepwarm pumps proved unreliable and therefore were removed and the non-ASME keepwarm pumps were re-installed. During NRC Inspection 50-482/84-55, the re-installation of the non-ASME pumps was evaluated and determined to be a deviation from WCGS's design commitments. License Condition 2.C(1) was issued requiring the non-ASME pumps be replaced with ASME Section III, Class 3, pumps prior to startup from the first refueling outage.
WCGS attempted to redesign / rework the ASME pumps to assure they would perform reliably.
Upon completion of the redesign / rework effort the ASME pumps were reinstalled prior to startup from the first refueling outage, which satisfied the license condition.
The results of the redesign / rework effort has proven to be less than completely successful.
The ASME pumps continue to perform below the reliability expectations of WCGS.
However, the non-ASME pumps initially installed by the vendor and temporarily utilized by WCNOC have proven to be more reliable in the industry than the ASME Section III, Class 3 pumps currently utilized.
The non-ASME pump to be installed at WCGS is designed and manufactured in 4
i accordance with an approved quality program.
The pump has been shown to be seismically qualified, hydro-tested to assure pressure boundary integrity, and the integral relief valve on the top of the pump has been replaced with a l
cover plate to prevent interference with the existing relief line.
The cover plate was hydro-tested as was the pump.
The non-ASME Section III, Class 3,
pump weight and center of gravity is slightly less that the ASME Section III, Class 3, pump, thus not affecting its seismic qualifications.
As was earlier stated the non-ASME pump to be installed at WCGS has been seismically qualified at another nuclear unit.
The seismic qualification report for the pump used at the other nuclear unit has been reviewed and the pump meets WCGS seismic criteria.
Therefore, the pump is capable of surviving a seismic event without loss of pressure boundary.
i
Attachment I to ET 95-0079 Page 5 of 6 The not a4E Section III, Class 3, replacement pump is equivalent to the ASME Section
.II, Class 3 pump.
The only difference is that the non-ASME pump is designed and fabricated to manuf acturers' standards rather than ASME Section III.
Controls commensurate with Section III were used for the non-ASME pump, and it is still seismically qualified.
As a passive safety-related lube oil pressure boundary, the pumps are technically equivalent.
The emergency diesel generator lube oil keepwarm system functions are to 1) maintain the oil in the sump in a warm condition to ensure a the emergency diesel will start within the required 12 seconds, 2) pre-lubricates the essential engine components and 3) maintains the oil purity by continuous filtration. The lube oil keepwarm pump function is to provide the circulation of the lube oil to ensure that the system functions are satisfied.
Pre-lubrication of the engine components is an economic consideration to reduce. unnecessary wear and to ensure the long term performance of the emergency diesel generator.
Also, the filtration performed by the keepwarm system only provides a bypass filtration process to the primary filtration and is provided only to eliminate unnecessary wear and to ensure the long term performance of the emergency diesel generators.
As identified in USAR Table 3.9(B)-15, the keepwarm pumps perform no active safety-related function.
Operation of the keepwarm pumps is not required following a design basis accident as discussed in Section 9.5.7.1.1 of the USAR.
The lube oil keepwarm pump only maintains the pressure boundary once the diesel generator is
- started, An engine driven lube oil pump operates while the diesel generator is running.
USAR Safety Design Basis states that to the extent practicable, the emergency diesel engine lubricating system is designed and fabricated to the codes consistent with the quality group classification assigned by Regulatory Guide 1.26, Revision 3,
" Quality Group Classifications and Standards for Water,
Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants" and the seismic category assigned by Regulatory Guide 1.29, Revision 3,
" Seismic Design Classification."
Regulatory Guide 1.26 Section B states that it does not cover systems such as instrument and service air, diesel engine and its generators and auxiliary support systems, diesel fuel, emergency and normal ventilation, fuel handling, and radioactive waste management systems, but that these systems should be designed, fabricated, erected, and tested to quality standards commensurate with the safety function to be performed.
Section C.2.b of the Regulatory Guide requires that cooling water and seal water systems or portions of these systems important to safety that are designed for functioning of components and systems important to safety, such as reactor coolant pumps, diesels, and control rooms, be Quality Group C (ASME Class III).
The keepwarm pumps are not an integral component of the cooling water or seal water support systems for the emergency diesel generators.
l This evaluation has concluded that the keepwarm pumps can be considered Quality Group D components that are seismically Category 1 qualified and 3
equivalent to the original supplied ASME keepwarm pumps.
j I
Historically, the existing ASME Code III, Class 3, pump has been proven less l
reliable than that of the non-ASME Code III, Class 3, pump.
In 1984, another utility with the same equipment changed out their ASME Code pump with a non-ASME pump.
In 1984, WCNOC provided justification to the NRC that temporary I
I
1 Attachment I to ET 95-0079
~
Page 6 of 6 i
use of this same non-ASME pump was acceptable.
Bechtel demonstrated that the non-ASME pump had proven reliable, was capable of surviving a seismic event, and was deemed suitable for interim use until the replacement ASME Section III, Class 3 pump could be installed.
ASME pumps are no longer available for this application and WCNOC is in the process of buying a pump which meets the guidance of Generic Letter 89-09.
Therefore, it is WCNOC's position that this non-ASME pump has been designed, fabricated, erected, and hydrostatically tested to a quality standard one step below that of a fully code-certified pump.
Based on the information presented above, the proposed deletion of the License Condition does not involve an unreviewed safety question and will not adversely affect or endanger the health or safety of the general public.
l l
i
(
I
Attcchment II to ET 95-0079 Page 1 of 3 l
ATTACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 1
i i
i
)
Attachment II to ET 95-0079 Page 2 of 3 No Significant Hazards Consideration Determination This exigent change proposes to delete License Condition 2.C(1), Attachment 1, contained in Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS).
This License Condition required that the emergency diesel generator lube oil keepwarm pumps for WCGS be replaced with ones satisfying ASME Section III, Class 3, requirements prior to startep following the first refueling outage.
On July 27, 1995, emergency diesel generator "A"
was declared inoperable and Technical Specification 3.8.1.1, Action b,
was entered.
This technical specification requires, in part, that the inoperable emergency diesel generator be returned to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit must be placed in at least hot standby with in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
f On July 28, 1995, the mechanical overspeed trip device on the "B"
emergency diesel generator actuated due to a possible governor adjustment problem and the diesel generator was declared inoperable and Technical Specification 3.8.1.1, Action f was entered.
This technical specification requires, in part, that one of the two inoperable emergency diesel generators be returned to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the unit must be placed in at least hot standby with in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Subsequently, the "A"
emergency diesel generator was started and run until the lube oil temperature was returned to within the required temperature band.
The "A"
emergency diesel generator was then declared operable with the ASME
)
Section III Class 3 keepwarm pump isolated.
WCNOC remains in Technical Specification 3.8.1.1, Action b, due to the inoperable "B"
emergency diesel generator. WCNOC will continue to periodically start the "A" emergency diesel generator until a non-ASME Section III, Class 3,
replacement pump can be installed or until the "B" emergency diesel generator governor ic repaired and I
the engine is returned to operable status.
Involve a Significant Increase in the Probability or Standard I Consequences of an Accident Previously Evaluated This proposed deletion of the License Condition does not involve a significant increase in the probability or consequence of an accident previously evaluated since the proposed installation of a non-ASME keepwarm pump does not change the function or performance requirements for the emergency diesel generator as described in the Updated Safety Analysis Report (USAR) and technical specifications.
The design of the non-ASME pump will be to the same performance requirements as the ASME pump.
The emergency diesel generator and associated keepwarm pump will continue to perform in a manner consistent with the assumptions in the USAR.
There will be no degradation in system performance, nor will there be an increase in the number of challenges to equipment assumed to function during an accident situation.
~ ~.- -.. -.
~
Attachment II to ET 95-0079 Page 3 of 3 Standard II -
Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated This proposed deletion of the License Condition does not create the possibility of a new or difference kind of accident from any previously evaluated since the non-ASME pump will be designed to the same performance requirements as the ASME pump.
The emergency diesel generator and associated keepwarm pump will continue to perform in a manner consistent with the assumptions in the USAR.
No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced. There will be no adverse effect or challenges imposed on any safety related system as a result of this exigent change to the Operating License.
l Standard III -
Involve a Significant Reduction in the Margin of Safety This proposed deletion of the License Condition does not involve a significant reduction in the margin of safety since the non-ASME pump was designed to the same performance requirements as the ASME pump and will perform in a manner consistent with the assumptions in the USAR.
The emergency diesel generator and associated keepwarm pump will continue to perform in a manner consistent with the assumptions in the USAR.
Based on the above discussions, it has been determined that the requested deletion of the License Condition does not:
involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; create the possibility of a new or different kind' of accident or condition over previous evaluations; nor involve a significant reduction in a margin of safety.
Therefore, the requested license amendment meets the requirements of 10 CFR 50.92(C), and does not involve a significant i
hazards consideration.
i l
l
Attcchm:nt III to ET 95-0079 Page 1 of 2 e
ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION O
4...
Attachment III to ET 95-0079 Page 2 of 2 t
Environmental Impact Determination I
This exigent change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) as specified below:
(i) the amendment involves no significant hazards consideration As demonstrated in Attachment II, the proposed change 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 effsite The proposed change does not involve a change to the facility or operating procedures that would cause an increase in the amounts of effluents or create new types of effluents.
The change to the License Condition does not involve any changes to any instrumentation setpoints, system operating parameters, or system accident mitigation capabilities, nor does this request affect the probability of any event initiators.
Thus, the request does not reduce the margin of safety to any licensed design parameter.
(iii) there is no significant increase in individual or cumulative occupational radiation exposure The request would not adversely affect tne operation of the reactor, and would not affect any system that would affect occupational radiation exposure.
The proposed change does not create additional exposure to personnel nor affect levels of radiation present, The change to the License Condition will 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 the proposed changes, and that the proposed changes meet the criteric 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.
Attechm:nt IV to ET 95-0079 Page 1 of 2 e
ATTACHMENT IV PROPOSED LICENSE CONDITION CHANGE 1
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i Attachment IV to ET 95-0079
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