ML20094B366

Application for Amend to License NPF-42,revising TS SR 4.7.6.c,d & E to Reflect Proposed Design Change to Output Rating of Charcoal Filter Adsorber Unit Heater in Pressurization Sys of CR Emergency Ventilation Sys

ML20094B366
Person / Time
Site:	Wolf Creek
Issue date:	10/24/1995
From:	Hagan R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20094B371	List: ML20094B366 ML20094B374
References
ET-95-0094, ET-95-94, NUDOCS 9511010002
Download: ML20094B366 (12)

Text

- - . . - . . - .-.- . - -_ . . _ - - _ - . - _ - - . - . - .-

t i , k-

. y

~

1 MR$LF CREEK NUCLEAR OPERATING CORPORATION i Hobert C. Ha October 24, 1995 ve. pre o.ni2an ng n nna l

ET 95-0094 l U. S. Nuclear Regulatory Commission

ATTN Document Control Desk

Mail Station P1-137 j Washington, D. C. 20555 3

I

Subject:

Docket No. 50-482: Revision to Technical Specification Surveillance Requirements 4.7.6.c,

d. and o ,

Gentlemen:

Thia letter transmita an application for amendment to Facility Operating Licenne No. NPF-42 for Wolf Creek Generating Station (WCOS). This licence amendment request propones revising Surveillance Requirement 4.7.6.e.4 to reflect a proposed design change to the output rating of the charcoal filter adsorber unit heater in the pressurization system j portion of the control room emergency ventilation system. Also, j Surveillance Requirements 4.7.6.c.2 and 4.7.6 d will be revised to i reflect a proposed change to the acceptance criteria for the testing of j carbon samples from the charcoal adsorbers of the control room emergency

! ventilation system.

I Attachment I provides a Safety Evaluation including a description of the  !

j proposed change, Attachment II provides a No Significant Hazarda  !

1 Consideration Determination and Attachment III provides an Environmental j Impset Determination. The specific changes to the technical i

specifications proposed by this request are provided in Attachment IV.

I i

. In accordance with 10 CFR 50.91, a copy of this application, with i attachmenta, is being provided to the designated Kansas State official, j This propoaod revision to the WCGS Technical Specifications will be fully implemented prior to startup from the eighth refueling outage, 4 following formal Nuclear Regulatory Commission approval.

I J

S00U 3 38A2A8882gg;gg;,,

P PDR (

' P.0, Box 411/ Burhngton KS 66839 / Phone: (316) 3%8831 An Equal Oportunity Employer WSCVET \

4' s t q

. .l s 1 1-RT 95-0094 4

- ~ "I j ' Page.2 of 2 , ,

l

3, i 1, '

i 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. '

1

{ - Very truly yours, 4

l' s

kf .

l R bert C. Hagan 1

RCH/jra. '

s

- Attachments I - Safety Evaluationr . . .

l

.II - No Significant Hazards Consideration Determination III - Environmental Impact Determination IV - Proposed Technical Specification Change 2

l

.! cca 'G. W. Allen (KDHE), w/a l I. J. Callan (NRC) , w/a .

D. F. Kirsch (NRC) , w/a l' J. F. Ringwald (NRC), w/a

• l J. C. Stone (NRC), w/a i

t l

A a

4 4

2 l'

e d

l .,l 1

(

6 T-c_ . .a...,m... . _ . _ _ _ . _ ..;a ,..., - ,, , .c . _

e

, . i

+

l .,. l i

l

. STATE or RANSAs ) ,,

' as

)

Comery or corrEY r 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 ham. read the foregoing document and known the content thereof that J '

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 ' J g Notary Put4c. State of Kanese I M Appt. Esperee WJ / *17 , BY . _L l Ro Et C. Hagan // _ l Vi e' President (/ I En ineering  ;

1 SUBSCRIBED and sworn to before me thin dd/ day of 8 C4. , 1995.

>tx b b .YL l<ktLA.

Notary P)ublic Expiration Date d4Mu d, / 7 9 7 f

'6 i k 1 Y

Attcchment I to ET 95-0094 Page 1 of 4 l

l l

ATTACHMENT I SAFETY EVALUATION l

l

Attcchment I to ET 95-0094 .

l ,

Page 2 of 4 l

Safety Evaluation Dranamed ek - a This license amendment request proposes to revise Surveillance Requirement f.7.6.e.4 to reflect a proposed design change to the output rating, from 15kW to 5kW, of the charcoal filter adsorber unit heater in the pressurization system portion of the control room emergency ventilation system (CREVS). Surveillance Requirements 4.7.6.c.2 and 4.7.6.d are also being revised to reflect a proposed change to the l acceptance criteria for the testing of carbon samples from the CREVS charcoal adsorbers. This change would adopt ASTM D 3803-1989 as the ,

laboratory tenting standard for control room filtration and control building pressurization charcoal adsorbers. Laboratory testing of the carbon samples taken from the charcoal adsorbers will be performed at 30 degrees Centigrade ('C) and 70% relative humidity for a methyl iodide penetration of 2%, instead of the current 1% limit.

Evaluation The design function of the control room pressurization system filter adsorber unit heater is to reduce the relative humidity of the' air entering the charcoal filter beds from design ambient conditions (i.e.,

100% relative humidity) to 70% relative humidity. The original design specified a heater with a rating of 15kW t 2kW to meet this functional requirement. However, review of associated design basis calculations indicates that this system requires only 2.09kW to meet the functional requirement. This includes additional margin to account for a 2 10%

voltage variation.

Reducing the heater capacity from 15kW 2kW to SkW ikW will provide sufficient operating margin and still meet CREVS' design basis requirements. In addition, the reduction in heat load output from the heater will reduce excess heat input to the control building during emergency conditions, thus increasing the margin of safety between the cooling capacity of the system air conditioning units and the building heat load (under accident conditions).

CREVS includes the control room air conditioning units (SGK04A,B), the control room filtration units (FGK01A,B), and the control building pressurization units (FGK02A,B), as shown in the Wolf Creek Generating Station (WCGS) Updated Safety Analysis Report (USAR) Figure 9.4-1.

CREVS is designed to maintain the habitability of the control room during a design basis loss of coolant accident (LOCA) by creating a positive pressure envelope within the control room, by filtering the supply air to remove particulates, and by providing charcoal adsorbers to . remove iodines. This will ensure that the doses to control room personnel will be within the limits of General Design Criterion (GDC) 19 of- Appendix A to 10 CFR 50. One of the key accident analysis assumptions utilized in the calculation that evaluated the potential radiological consequences to control room personnel from a LOCA was the filter decontamination ef ficiency of 95%. The flow rates through the

' charcoal flitration units are limited to 2000 t 10% cubic feet per

Attcchment I to ET 95-0094 Page 3 of 4 minute (CFM), in accordance with Technical Specification 3/4.7.6.c.3.

This will maintain the average atmospheric residence time greater than or equal to 0.25 seconda. Charcoal camples are routinely touted every eighteen monthat upon acheiving total run time of 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />; and l following a significant event or activity, such as painting, welding, or fire, which could potentially create fumen in an amount that could affect charcoal filter efficiency. The charcoal sample is analyzed by a i tanting laboratory to specified conditions reprenentative of service during a design basis accident. The tenting protocol for these camples is being revised to reflect testing per ASTM D 3803-1989 at 30*C and 70%

relative humidity for a methyl iodido penetration not to exceed 2%.

The 30'C and 70% relative humidity test to be performed on FGK01A,B and FGK02A,B in representative of the postulated conditions for the control room after a design basis LOCA. The current specification 3/4.7.6 penetration limit of 1% for testing at 80*C and 70% relative humidity per test standard RDT M-16-1T is less conservative than a 2% penetration limit for testing at 30*C and 70% relative humidity, due to the more stringent tolerance placed upon temperature and humidity in ASTM D 3803-1989, as well as the test being performed at the lower temperature of 30*C. Thus, testing the charcoal using the new protocol will provide greater assurance that the charcoal filters will perform at an ef ficiency of at least 95%. Technical Specifications 4.7.6.c.2 and 4.7.6.d are being changed to specify the new protocol and roference ASTM D 3803-1989.

Unreviewad Jafety Ouagtlen Evaluation The changes to the technical specifications discussed above do not involve an unreviewed safety question because operation of the WCGS with these changes would not:

1. Increase the probability of occurrence or the consequences of an Accident or malfunction of equipment important to safety previounly evaluated in the safetv analysin report.

The requested changes to the heater capacity and the surveillance acceptance criteria for the control room emergency ventilation system will not affect the method of operation of the system. The new heater capacity will still exceed filter operational requiremento and safety margin by a significant amount. In addition, the testing of the charcoal filter samples will continue to be performed in accordance with NRC-approved methods and acceptance criteria. Therefore, the proposed changes will not significantly increase the consequences of an accident or malfunction of equipment important to safety previously evaluated in the USAR.

2, create a ponnibility for an accident or malfunction of a different tyne than _previously evaluated in the maf'ety analysin report.

Attachm:nt I to ET 95-0094 Page 4 of 4 The requested change to the heater capacity in the control 7.oom emergency ve.ntilation system will not affect the method of operation of the system, and the new heater capacity will still i Since l exceed filter operational requirements and safety margin.  !

only the heater size is being changed and system operation is not being modified as a result of this change, then no new or different accidents other than those already evaluated will be l created by this change, The changes to the surveillance ,

requiremento are being made to adopt current NRC-approved methods l of testing charcoal samples. These changes will not affect the method of< operation of the applicable systems and the laboratory testing will continue to demonstrate the required adsorber performance after a design-bania LOCA.

l

3. Reduce the margin of safety an defined in the bases for any Technical Specification.

The requested change to the heater capacity in the control room emergency ventilation system will reduce the heater output of the system, but the new heater capacity will still exceed filter operational requirements and safety margin. Therefore, this change will not reduce the margin of safety of the control room emergency ventilation system filter operation. The new charcoal adsorber sample laboratory testing protocol is more stringent than the current testing practice and meets current NRC-approved test methods. The new testing criteria will continue to demonstrate the required adsorber performance after a design-basis LOCA and will not affect the filter system perf ormance. Therefore, this change will also not reduce the margin of safety of the control room ventilation system filter operation.

Based on the above discussions and the no significant hazards consideration determination presented in Attachment II, the proposed changes do 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 reduce the margin of safety as defined in the basis for any technical specification. Therefore, the proposed changes do not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.

L1

Atttchm:nt II to ET 95-0094 f

i Page 1 of 3 j.

I '

{

t l

ATTACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION I

l 4

______________ - -~

Attachmsnt II to ET 95-0094 Page 2 of 3.

No Significant Hazards Consideration Determination This license amendment request proposes to revise Surveillance Requirement 4.7.6.e.4 to reflect a proposed design change to the output rating, from 15kW to SkW, of the charcoal filter adsorber unit heater in the pressurization system portion of the control room emergency ventilation system (CREVS). Surveillance - RequirWments 4.7.6.c.2 and 4.7.6.d are also being revised to reflect a proposed change to the acceptance criteria for the testing of carbon samples from the CREVS charcoal adsorbers. This change would adopt ASTM D 3803-1989 as the laboratory testing standard for control room filtration and control i building pressurization charcoal adsorbers. Laboratory testing of the carbon samples taken from the charcoal adsorbers will be performed at 30 degrees Centigrade ('C) and 70% relative humidity for a methyl iodide ,

penetration of 2%, inctead of the current 1% limit. )

4 Standard I - Involve a Significant Increase in the Probability or 1 Consequences of an Accident Previously Evaluated The design function of the filter adsorber unit heater in the pressurization system portion of CREVS is to reduce the relative humidity of the air entering the charcoal filter beds to 70% relative humidity. Although the original design specified a heater with a rating of 15 kW, review of ' the design basis calculation for this syscem indicates that only 2.09 kW is actually required (including applicable margins to allow for voltage variations) . The proposed change to the CREVS heaters' output rating from 15 kW to 5 kW will not affect the method of operation of the system, and the new heater capacity will  !

I still exceed filter operational requirements and safety margin. Neither the heater change nor the charcoal testing protocol changes will affect system operation or performance, nor do they affect the probability of any event initiators. These changes do not affect any Engineered Safety Features actuation setpoints or accident mitigation capabilities.

The ifore, the proposed changes will not significantly increase the l

u ....equences of an accident or malfunction of equipment imp ,c. ant to safety previously evaluated in the USAR.

Standard II - Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The requested change to the CREVS heaters' output rating and the changes to the charcoal sample testing protocol will not affect the method of operation of the system, and the new heater capacity will still exceed filter operational requirements and safety margin by a significant amount. The proposed changes only affect the heater size in the system "

and the testing criteria for the charcoal samples. No new or different accident scenarios, trensient precursors, failure mechanisms, or limiting single failures will be introduced as a result of these changes. Therefore, the possibility of a new or different kind of accident other than those already evaluated will not be created by this change.

. . -. -. _ -_ ~ _ . - . , - .~ - .

-Attcchment II.to-ET 95-0094 Page 3 of 3 9

-standard III - Involve a Significant Reduction in the Margin of Safety The. requested change to the CREVS heaters' output rating will reduce the heater output of the system, but the new heater capacity will still exceed filter operational requirements and safety margin by a significant amount. In addition, the reduction in heat load output from the heater will increase the design margin between the cooling capacity of the system air conditioning units nnd the building heat load. The new charcoal adsorber sample laboratory testing protocol is more stringent than the ctrrent testing practice and more - accurately demonstrates the required performance of the adsorbers following a design basis LOCA. Therefore, these changes will not reduce the margin of safety of the CREVS filter operation. ,

Based on the above discussions, it has been determined that the requested technical specification changes do not involve a significant increase in the probability or consequences of an accident or other

-adverse condition over 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.

Therefore, the requested license amendment does not involve a significant hazards consideration.

1

.l l

l

\

l I

l i

~

Attcchment III to ET 95-0094 l Page 1 of 2 l l

8 4

ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION

Attachmsnt III to ET 95-0094 Page 2 of 2 f

. Environmental Impact Determination This amendment request 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 a

As demonstrated in Attachment II, the propored change does not involve any significant hazards consideration.

(ii) there is no significant change in the types (, significant increase in the amounts of any effluents that may be released

) offsite

$ The proposed changes do not involve a change to the facility or operating procedures which would create new types of effluents. The reduction in heater capacity will still provide a significant margin  !

i over system operating requirements to reduce incoming air relative humidity to the required limits. The change in charcoal sample testing l protocol will not affect system performance or operation. Therefore, all offsite and control room doses will remain within the limits of 10 CFR 100 and 10 CFR 50 Appendix A, GDC 19.

(iii) there is no significant increase in individual or cumulative '

occupation radiation exposure

, The reduction in the control room emergency ventilation system filter heater capacity will not affect system operation and will not reduce filter efficiency. The change in charcoal sample testing protocol will also not reduce filter efficiency. Thus, these changes will not result in a significant increase in individual or cumulative occupational j 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 criteria 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, k

f I