ML20087J391
| ML20087J391 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/16/1995 |
| From: | Hagan R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20087J395 | List: |
| References | |
| ET-95-0065, ET-95-65, GL-91-08, GL-91-8, NUDOCS 9508210132 | |
| Download: ML20087J391 (10) | |
Text
p
?;
-;4 f J
-)
)
W$1LF CREEK
=
NUCLEAR OPERATING CORPORATION Flobert C. Hagan Vce Preskient Engmeenng August 16, 1995 ET 95-0065' U.-S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555 Reference Letter CO 95-0002 dated March 24, 1995, from R. N. Johannes, WCNOC, to the NRC
Subject:
Docket No. 50-482: Removal of Technical Specification Table 3.6-1 Gentlemen:
The reference transmitted an application for amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS).
This license amendment request proposes to revise Technical Specification 1.7,
" Containment Integrity," Technical Specification 3/4.6.1,
" Containment Integrity," and Technical Specification 3/4.6.3,
" Containment Isolation valves."
These proposed changes will remove Technical Specification Table 3.6-1, acontainment Isolation Valves," to Wolf. Creek Generating Station (WCGS) procedures.
This proposed change is in accordance with the guidance provided in Generic Letter 91-00, " Removal of Component Lists from Technical Specifications," dated May 6,
1991.
The purpose of this letter is to submit corrected markup pages for Technical ll Specification 1.7 and Technical Specification 3/4.6.3.
These corrected pages I-reflect changes to our original submittal, as discussed on May 24, 1995, with Mr.
J.
C.
Stone, Office of Nuclear Reactor Regulation Project Manager for WCGS.
These corrections incorporate wording from Generic Letter 91-08 which had inadvertently been omitted from our original submittal.
These changes do not alter the conclusions of the Safety Evaluation or the Significant Hazards consideration Determination provided with our original submittal.
WCNOC has also identified an additional footnote to be added to Technical Specification 3.6.3.
This note would apply to action statement b.,
and would allow ' up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following penetration isolation in which to cycle the-Component Cooling Water System Reactor Coolant Pump seal water supply and -
return valves as needed to complete testing required to return the inoperable isolation valve to OPERABLE status.
C#, C R Y) Q 9508210132 950816 PDR ADOCK 05000482 P
PDR P.O. Box 411/ Burlington, KS 66839 / Phone: (316) 364-8831 An Equal Opportunny Ernployer MWHC/ VET l0 t
. ~..
i
')
f
.RT.95-0065 iPage 2 of 2-
,f A revised ' Safety Evaluation to include the new footnote is provided in-
. Attachment I,-
and Attachment :II provides.a; revised. Significant Hazards
. Consideration. Determination.
These attachments ' replace ~ the ' corresponding attachments in our original submittal.
The.two pages provided in-Attachment-III -replace the corresponding.pages in'. Attachment IV of our1 original submittal.
(
In accordance with 10 CFR 50. 91,. a copy of this revision to our _ original' I
application, with attachments, is being provided to ' the designated ' Kansas State Official.
l v
-If you ' have any questions concerning 'this matter,' please. contact me at (316).364-8831, extension
- 4553, or Mr.
Richard D.
.Flannigan,.. at l
extension 4500.
i very truly yours,
.i k
jj Robert C. Hagan 1
RCH/jra Attachments I - Safety Evaluation j
II - Significant Hazards Consideration Determination-III - Revised Proposed Technical Specification Change l
cci G. W. Allen (KDHE), w/a L. J. Callan (NRC), w/a D. F. Kirsch (NRC), w/a l
'J. F. 'Ringwald (NRC), w/a J. C. Stone (NRC), w/a t
1 i
f i
- . r; Att:chment'I to ET 95-0065 Page 1 of 5 g
ATTACHMENT I REVISED PROPOSED TECHNICAL SPECIFICATION CHANGES
Attachment I to ET 95-0065 Page 2 of 5 Safety Evaluation Ergposed change This license amendment request proposes to revise the Wolf Creek Generating Station (WCGS) Technical Specifications to relocate Technical Specification Table 3.6-1,
" Containment Isolation valves," to Wolf Creek Generating Station procedures, which are subject to the change control provisions in the Administrative Controls Section of the Technical Specifications.
This request is being made in accordance with the guidance provided in Generic Letter (GL) 91-08, " Removal of Component Lists from Technical Specifications," dated May 6, 1991.
The proposed Technical Specification changes to relocate Technical Specification Table 3.6-1 consist of:
1.
Deleting references to the table from Technical Specification 1.7, 3/4.6.1 and 3/4.6.3,
- 2. Adding wording to Surveillance Requirement 4.6.1.la to exempt valves opened under administrative control as permitted by Technical Specification 3/4.6.4, 3.
Adding a note to LCO 3.6.3 to indicate that Technical Specification 3.0.4 does not apply, and that locked or sealed-closed valves may be opened under administrative control, and 4.
Adding a note to LCO 3.6.3 to allow 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as the allowed outage time for the Component Cooling Water (CCW),ystem Reactor Coolant Pump (RCP) seal water supply and return valves (EG HV-58, 59, 60, 61, 62, 127, 130, 131, 132, and 133).
Bases Section 3/4.6.3 will also be revised in accordance with the guidance i
provided in GL 91-08.
j l
Rackground Maintaining containment integrity prevents excessive radioactivity from passing from the containment to the atmosphere in the event of a release of radioactive material to the containment.
Containment integrity is provided by the containment structure and by isolating the various penetrations that pass j
through the containment structure walls.
1 The containment isolation valves are part of the containment piping penetration isolation design.
The function of these valves is to be closed or to automatically close to limit the release of radioactive fission products to the environment.
Technical Specification 3/4.6.3 establishes Technical Specification requirements for containment isolation valves and Technical Specification Table 3.6-1 specifically identifies valves for which operability ensures that the ' containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material within the containment or pressurization of the containment.
" Removal of Component Lists from Technical Specifications," provides guidance to licensees pursuing amendments to remove component lists from Technical Specifications.
In accordance with the provided
1
\\
)
Attachm3nt I.to ET 95-0065 Page 3 of,5 i
c '1 J
' l
. guidance, component lists removed from Technical Specifications must' be relocated in plant procedures that are sulaject to the change control provisions l
in the Administrative Controls Section of the Technical Specifications.
These
' changes allow component lists to-be updated without license amendments.
- i Technical Specification references to component lists are to be replaced with i
general statements that. describe the types 'of components to which the i
requirements apply.
Since any change to procedural component lists will be subject to the provisions of Section 50.59 of Title 10 of the Code of Federal -
{
Regulations (10 CFR 50. 59), adequate controls will exist to ensure that these components satisfy the applicable Technical Specification requirements.
The proposed change removes Technical Specification Table 3.6-1 in accordance
' i with GL 91-08.
Specifications that refer to Table 3.6-1 are revised to reference the applicable valves by function.
The proposed changes as described I
above allow Table 3.6-1 to be removed from the Technical Specifications without t
altering existing Technical Specification requirements or those components to f
which they apply.
{
t 4
Evaluation
]
Relocation of Table 3.6-1 from the WCGS Technical Specifications to WCGS plant procedures would permit administrative control of changes ' to the containment isolation valve list.
Currently, updating the containment isolation valve list i'
requires prior commission approval utilizing the license amendment process'in accordance with 10 CFR 50.90.
Once relocated, any change to the containment isolation valve list contained in plant procedures would be subject to the l
requirements specified in Administrative Controls, Section 6, of the Technical specifications on changes to plant procedures.
In addition, containment i
isolation valves are listed by penetration in Updated Safety Analysis Report (USAR) Figure 6.2.4-1, which identifies each containment penetration and its associated valves and isolation design features.
Thus, any change to the containment isolation valve list would constitute a change to the facility, and
)
would be subject to the provisions of 10 CFR 50.59.
Therefore, the procedure change control provisions of the technical specifications, and the current administrative controls over changes to the facility as described in the USAR,
{
would provide adequate means to control changes to the valve list, once i
incorporated into WCGS plant procedures.
l As stated in GL 91-08, technical specifications may be stated in general terms that describe the types of components to which the requirements apply.
This i
provides an acceptable alternative to identify components by their plant identification number as currently listed in tables of technical specification components.
The removal of component lists is acceptable because it does not i
alter existing technical specification requirements or those components to which they apply.
Generic Letter 91-08 states that this technical specification change will cause the LCo remedial actions and surveillance requirements of the technical specifications to apply to all valves classified as containment isolation valves by the plant licensing basis.
Containment isolation valves in WCGS licensing basis (USAR Figure 6.2.4-1) will be administratively controlled by
}
the requirements of Technical Specification 3/4.6.1 and Technical Specification i
3/4.6.3.
Future changes to the relocated table and to USAR Figure 6.2.4-1 will be controlled by the 10 CFR 50.59 review process.
This process provides proper
-..,y
- =*
e
-r m
v
--,r
~
Attachm:nt I to ET 95-0065 Page 4 of,5 levels of review and approval of changes and for the identification of. any unreviewed saf ety question in accordance with 10 CFR 50.59.
Records of the changes are maintained and an annual report is submitted to the NRC that includes a brief description of changes and a summary of the safety evaluation of each in accordance with 10 CFR 50.59.
Relocation of Table 3.6-1 does not affect the purpose or information provided in USAR Figure 6.2.4-1.
Technical Specification Table 3.6-1 identifies certain valves that may be opened during plant operation as long as the valves are administrative 1y controlled.
These valves are required to be opened for testing, maintenance, and other activities.
Administrative control of these valves when opened in Modes 1 e sugh 4 is required since rapid closure would be necessary to isolate.
the cun.ainment during accident conditions.
Technical Specification 3/4.6.3 is revised to retain the exception of the requirements to those valves under administrative control.
This control is provided by appropriate plant procedures.
Any changes to these procedures would be reviewed under 10 CFR 50.E9, as described above.
The valve closure time requirements listed in Table 3.6-1 are raintained in appropriate plant procedures, as well as in USAR Figure 6.2.4-1.
Any changes to these closure time requirements would be reviewed under the provisions of 10 CFR 50.59, as described above.
Therefore, removing Table 3.6-1 from the technical specifications will not alter the valve stroke time requirements.
The additional footnote to Action Statement b is needed to allow up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to energize and cycle CCW motor-operated valves (MOVs) in order to perform diagnostic testing required to return the inoperable MOV to OPERABLE status.
This note would be applicable only to the valves in the CCW water supply and return lines supplying the RCP motors (seals) and thermal barrier heat exchangers.
The affected penetrations (74, 75 and 76) contain valves EG HV-58, 59, 60, 61, 62, 127, 130, 131, 132, and 133.
This diagnostic testing could take up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to complete for these valves while in power operation, and j
must be completed in order to declare the MOV OPERABLE.
The current Action b
'{
allows only 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, at which time the MOV must be closed.
This footnote would allow sufficient time to complete the testing required to return the MOV to OPERABLE status.
Allowing 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for these valves instead of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is acceptable because these valves are in a closed system (isolated from the RCS with flow through the penetrations) and the penetration can still be isolated by the in-containment isolation device.
Thus, extending the allowed outage time for these valves from 4 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would not result in an increase in containment leakage that would exceed limits assumed in the safety analyses for a Loss of Coolant Accident (LOCA).
The proposed revision does not alter the requirements for containment isolation i
valve operability currently in the technical specifications.
The LCO and Surveillance Requirements would be retained in the revised technical specifications.
Therefore, the proposed changes would not affect the meaning, application, and function of the technical specification requirements for the containment isolation valves currently listed in Technical Specification Table 3.6-1.
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
Attcchment I to ET GS-0065 Page 5.of,5 l reports or create a possibility for an accident or. malfunction of a different I
type than any previously evaluated in the safety analysis reports 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.
9 s
T I
)
i i
l
=
j.
f Ee IAttcchment II to ET 95-0065 Page 1 of,3 i
i L
1 1
l ATTACHMENT II t
)
NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION i
)
)
I i
1
i Attachment II to ET 95-0065
'Page 2 of 3 i
No Significant Hazards Consideration Determination f
This license amendment request proposes a revision to Technical Specification 3/4.6.3, to remove Table '3.6-1,
" Containment Isolation Valves," from the technical specificationt,.
The current technical specification requirements concerning containment isolation valves would continue to be maintained under l
administrative control, in accordance with the revised Technical Specification j
3/4.6.3.
Additional technical specification sections and Bases sections are revised to remove reference to Table 3.6-1 and to clarify the administrative control requirements, as follows:
.i
- 1. Deleting references to the table from Technical Specification 1.7, 3/4.6.1 and 3/4.6.3,
- 2. Adding wording to Surveillance Requirement 4. 6.1.la to exempt valves opened I
under administrative control as permitted by Technical Specification l
3/4.6.4, l
- 3. - Adding a note to LCO 3.6.3 to indicate that Technical Specification 3.0.4 does not apply, and that locked or sealed-closed valves may be opened under administrative control, and
- 4. Adding a note to LCO 3.6.3'to allow 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as the allowed outage time for the Component Cooling Water (CCW) System Reactor Coolant Pump (RCP) seal water supply and return valves (EG HV-58, 59, 60, 61, 62, 127, 130, 131, j
132, and 133).
Bases Section 3/4.6.3 will also be revised in accordance with the guidance 1
provided in GL 91-08, to reflect the above changes.
-l Standard I - Involve a Significant Increase in the Probability or Consequences
-f of an Accident Previously Evaluated The proposed changes simplify the technical specifications, meet the regulatory l
requirements for control of containment isolation, and are consistent with-the l
guidelines of GL 91-08.
The procedural details of Technica) Specification I
Table 3.6-1 have not been changed, but only relocated to a different-
)
controlling document.
The proposed changes are administrative in nature, should result in improved administrative practices, and do not affect plant operations. _
does not affect the severity of any accident previously-The addition of the footnote to allow up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for valve testing the CCW MOVs evaluated.
This footnote does not impact plant safety since the second
]
isolation device in the affected penetrations would still be available to provide isolation between the RCS and the outside atmosphere, i
The probability of occurrence of a previously evaluated accident is not increased because this change does not introduce any new potential accident initiatinct conditions.
The consequences of an accident previously evaluated is not iner sed because the ability of containment to restrict the release of any fission product radioactivity to the environment will not be degraded by this change.
t
.- ~
1 l
'Attachmsnt'II to ET 95-0065 Page 3 of 3 i
Standard II - Create the Possibility of a New or Different Kind of Accident front any Previously Evaluated i
The proposed changes are administrative in nature, do not result in physical alterations or changes to the operation of the plant, and cause no change in the method by which any safety-related system performs its function. The addition of the footnote to allow up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for valve. testing the.CCW MOVs i
does not affect the severity of any accident previously evaluated.
The additional time provides assurance that the inoperable valve is in proper working order prior to returning it to CPERABLE status.
Therefore, this l
proposed change will not create the possibility of a new or different kind of i
accident from any previously evaluated.
Standard III - Involve a Significant Reduction in the Margin of Safety The administrative change to relocate Technical Specification Table 3.6-1 to appropriate plant procedures does not alter the basic regulatory requirements for containment isolation and will not adversely affect containment isolation
{
capability for credible accident scenarios. Adequate control of the content of the table is assured by existing plant procedures.
The additional footnote to extend the allowed outage time to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the CCW MOVs does not affect containment isolation capability since the second isolation device in the affected penetrations would still be available to provide isolation between the
]
RCS and the outside atmosphere, and to ensure that a release of radioactive 1
material to the environment following an accident will not exceed the assumptions used in the LOCA Analyses.
The proposed relocation of Technical Specification Table 3.6-1 does not alter the requirements for containment isolation valve operability currently in the technical specifications.
The LCO and Surveillance Requirements would be retained in the revised technical specifications.
Therefore, the proposed change will not affect the meaning, application, ' and function of the current technical specification requirements for the valves in Table 3.6-1.
Based on the above discussions, it has been determined that the requested technical specification revision does not involve a significant increase in the 1
probability or consequences of an accident or other adverse condition over i
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.
i l
.>