ML20101F886
| ML20101F886 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/21/1984 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| KMLNRC-84-236, NUDOCS 8412270352 | |
| Download: ML20101F886 (6) | |
Text
l KANSAS GAS AND ELECTRIC COMPANY THE ELECTAC COMPANY CLENN L. MOESTER VER pets 40am? - muctaan December 21, 1984 Mr. Hat.. R. Denton, Dire.: tor Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 KMLNRC 84-236 Re:
Docket No. STN 50-482 Ref: Letter of 12/4/84 from TMNovak, NRC, to GLKoester, KG&E Subj: Wolf Creek Draft Operating License
Dear Mr. Denton:
The Reference provided a copy of the Draft Operating License for Wolf Creek Generating Station, Unit No. 1.
Comments on the license were requested of KG&E, in writing, by the Reference.
KG&E's comments on the draf t license are provided in the Attachment. KG&E requests that the NRC address these comments in writing or in a meeting with KG&E prior to NRC issuance of the License.
Yours very truly,
[///
GLK bb,w/a xc:PO'Connor (2), w/a HBundy,w/a WGGuldemond,w/a 0412270352 041221 PDRADOCK05000g
^
201 N. Market - WicNta, Kansas - MsR Address: PO. Don too I Wctuts, Kansas 67201 - Telephone: Area Code (316) 2616451
V Attachment to IDENIC 84-236 -
Connants on the Draft Wolf Creek Operating License v.
Section Cannant The Enclosure to this Attachment provides a listing of typogrThical errors in the
. Draft License.
2.C. (3)
The Applicants were unauere that antitrust provisions would be carried over to the Operating License based upon the Wolf Creek Construction Permit-Amendment and the way the Operations License was filed.
Please provide Appendix C for our review.
2.C.(4)
Wolf Creek SSER 94 contains extensive dis-cussions in Section 3.11 by the lac on err-
- vironsental qualification of equipment and should be referenced in the license.
2.C. (4) (a)
The date given in the condition is not ne-cessary. KG6E suggests that the condition could be rewritten as follows:
"KG6E shall environmentally qualify all electrical equipment according to the prcr-visions of 10CFI60.49".
10CrR50.49 contains provisions which allow the Director of the Office of Nuclear Reactor Regulation to review and determine if a nuclear plant can be safely operated pending conpletion of equipment qualification.
Such reviews could, in exceptional
- cases, allow qualification coupletion beyond the proposed date.
In principle, however, the proposed license condition represents an attenyt to duplicate in part but not in total a Consnission rog-ulation. Section 2.C of the draft license already inposes "all rules, regulations, and orders of the Conmission..." on the licensees. Thus, the provisions of 10CFR50.
49 ought to take precedence over a poten-tially more limiting provision of the li-cense and Section 2.C(4)(a) should be elim-inated from the license.
6-
.n.
2.C.5 Acomptable seismic qualification testing has been coupleted for all required equipment.-
ll This is docuented in the following letters:
~
SLNIC 84-0101, SLNIC 84-4118, SURE 84-0120, SUEC, 84-0123, SLNIC 84-0131 and SLNIC 84-0135.. Therefore, this condition should be deleted.
2.C. (6) (a)
At the time the license is. issued, the
- i, SNLPPS FSAR will be updated with a Revision.
l 17 and the Wolf Creek FSAR Addendum will have a Revision 15. KGEE suggests that the NIC reference the final, pre-license i:
docketed FSAR status.
2.C. (6) (b) & (c)
The proposed license condition would pro-hibit KGEE from making changes to the fire protection program pursuant to 10CFR50.59.
Changes to the facility and to procedures without prior en==nission approval are alloe i
ed by 10CFR50.59 unless the change involves p
a change in the technical specifications or "an unreviewed safety question". An unre-viewed safety question is defined by 2
10CFR50.59 as one which (1) increases the D
probabilit.y or the consequences of an ac-cident previously evaluated in the FSAR, (2) i
[
creates the possibility of.a previously un--
l evaluated type of accident, or (3) reduces 1
l the margin of safety as defined in the basis of a technical specification. 'the 10CFR50.
59 procedure is widely used and understood throughout the nuclear industry and within i
the NIC.
E The proposed license condition establishes l ~
a new and different type of test for deter-i mining when prior hinsion approval is needed, i.e., for those changes that
" decrease the level of fire protection in the plant." ~ The NIC's proposed wording does not even limit the scope of this i
i condition to fire protection in safety-j related areas of the plant. It is inconsistent to set different standards for fire protection than those estatr-i lished by 10CFR50.59 for other safety-
~
related systess..KG&E can make changes to safety-related systems, for exanple the 5
RHR system, without prior enemniasion approval if the tests of 10CFR50.59 are i
satisfied. Thus, creating another set i
of standards for fire protection s
features is not warranted.
j 1
.. ~.
y 6
4 10CFR50.54(h) providesithat the operating s
license be " subject to...'.all rules, reg-T ulations, and orders of:the Consnission". -
7,
~iThe draft' license contains the same language'
~
.in~Section 2.C.
Thus,:the provisions of
~
10CFR50.59 'ought to take procedence over the-inconsistent provision of the proposed-license.
Where the Consnission has thought it inpor--
" tant' enough, it has' specifically written -
. intoiregulations provisions like the pro-f posed' license condition.7 For exangle:
'1.
10CPR50.54(a) (3)
T' t
- 2. ' 10CFR 50.54(1-1) -
3.
In the absence of similar language for the-fire protection program, the general stand-ards of 10CFR50.59 must control. Otherwise, the NRC staff would be-free to change any NRC regulation sinply by putting an incore sistant provision in an operating license.
2.C.(7)
Assuming the technical requirenents of At-tachment 2 are identical to those given in to PPF-30, KG&E has no consnents. If this is not the case, the NBC nust provide a copy of Attachnent 2 to NPF-32 for KG&E review and comment.
2.C.(8) h Wolf Creek SER and Supplements do not have a Section 22.2. This cordition should refer to Section 22.0, "TMI-2 Requirements."
2.C. (8) (b)
Delete Wolf Creek SSER #1 from the title as it does not contain a discussion on item II.B.3.
SSER 44 contains open items-that KG&E assumes will be addressed and closed in SSER #5.
2.C. (9)
The Wolf Creek SER issued in April 1982 only addresses the SNLPPS FSAR through Revision 8 and the Wolf Credt FSAR Addendtsn through Revision 8 As noted under 2.C.(6)(a), KG&E has made several revisions beyond those addressed. Several of these revisions have altered our Initial Test Program. KG&E asstnes that SSER f 5 will address and close out the revisions.
n r
2.C.(15)
KGE's conmitments to the Generic Letter are described in 1008C 84-023, dated February 29, 1984.
2.E.
W e NiC has referenced some inappropriate letters and has not included the latest revisions of the various plans in this Section. % e first nine lines of the draft are gorrect. ~ Replacing the second nine lines'with the following will provide the proper status:
"May 8,1984, Revision 4, transmitted by letter dated August 15, 1984, Revi-sion 5, transmitted by letter data!
September 28, 1984, and Revision 6, transmitted by letter dated Novenber 30, 1984; " Safeguards Contingency Plan", Revision 0, transmitted by letter dated February 8,1980, Revi-sion 1, transmitted by letter dated March 31, 1982, Revision 4, trane-mitted by letter dated August 22, 1984, and Revision 6, transmitted by letter dated Novenber 30, 1984; and the
" Security Training and Qualifications Plan", Revision 0, transmitted by letter dated July 30, 1981, Revision 1, transmitted by letter dated March 31, 1982, and Revision 6, transmitted by letter dated Novenber 30, 1984".
At the suggestion of Region IV personne),
KGE started revising all three of the plans at the same tine. However, with this prac-tice one or two of the plans may not have any pages revised when the other plan (s) is revised.
%is was the case for the Plan Revisions not submitted.
J
~
r lihclosure-to Attachment to KMLNIC 84-236
. a.
..~ e.
t Wolf Creek Draft Operating License
~-
,.. Typographical Errors s
.w' t a g,
Section f
Comment Footnote
' ~ :The' formal-names of KGE and KCPL are in-correct. The names are properly reflected In Section 1.A. -
2.B.(4)
The "of" at the end of the secord line should be "or".
2.B. (5) -
To be consistent with the format used in iother paragraphs,.there should be.a conan
(,) between KGB and pursuant in the first
~
line.
2.C.(7)
To be consistent with the other heading titles, replace the comma (,) after the nunber five (5) by the word "and".
2.C. (8) (d)
SSER #3 should be SSER 95.
2.C. (9) (f)
Add "the" between "in" and " test" in the first line.
2.D.
The verb in the first sentence should be "is" not "are".
.