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Forwards Changes to Final Draft Tech Specs,As Discussed W/ NRC During Meetings on 850117,18,24 & 25.Rev to Final Draft Includes Changes in Limiting Condition for Operation & Surveillance Requirements
	ML20114B416
Person / Time
Site:	Wolf Creek
Issue date:	01/25/1985
From:	Petrick N; STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM
To:	Harold Denton; Office of Nuclear Reactor Regulation
References
	SLNRC-85-4, NUDOCS 8501290156
	Download: ML20114B416 (11)
	v • d • e

P SNUPPS Stenderdised Nucleer Unit Power Plant System 5 Choke Chern Aced Nicholas A. Petrick Rockville, Meryland 20850 Executive Director (30 0 880401o January 25, 1985 SLNBC 85-4 FILE: 0543 SUBJ: Wolf Creek Technical Specifications Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory (bnmission Washington, D.C. 20555 Docket No. SIN 50-482 Refs: 1) KG3 (G. L. Koester) letter to NRC (H. R. Denton)', dated 12/10/84, Same Subject

2) NRC (D. G. Eisenhut) letter to KGE (G. L. Koester)~, dated 11/7/84, Same Subject

3) SINRC 85-2,1/18/85, Sane Subject

Dear Mr. Denton:

Reference 1 forwarded KGE's comments on the Final Draft version of Wolf Creek's Technical Specifications as issued by reference

2. Since reference I, several other changes have been identified which were forwarded with reference 3 and this letter. These changes were discussed with mernbers of your staff during meetings on rJanuary 17, 18, 24, and 25, 1985.

Very truly yours,

%<w Nicholas A. Petrick rJHR/bds/6a10 Attachnents cc: G. L.'Koester KGE

'J. M. Evans KCPL D. F. Schnell UE

'J. Neisler/B. Little USNRC/ CAL H. Bundy USNBC/WC W. L. Ebrney. USNRC/RIII D.'R. Hunter USNRC/RIV 8501290156 850125

{DRADOCK 05000482 PDR OO(

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l SOURCE RANGE RESPONSE TIME TESTING I

e During the review of Wolf Creek's Technical Specifications the NBC

(Reactor Systems Branch) raised the question of why the Source j and Intermediate Range response times are "N/A" in Table 3.3-2.

These entries are also listed as "NA" in both revision 4 and draft E

revision 5 of the Westinghouse PWR Standard Technical Specifications.

E Investigation with Westinghouse revealed that these times are "N/A"

! because the Source and Intemediate Range instrments are not credited

[ in any safety analysis for protection during accident conditions.

Westinghouse safety analyses assmes only the Power Range instrmen-

! tation for protection.

! Historically, the NBC has accepted the argument that since the Source j Range instrmentation is required to be operable in mdes 3, 4, and 5 m and since the reactor trip frm the Source Range would occur earlier y than the trip from the Power Range, reliance on the Source Range

[. trip was acceptable. Operability of Power Range instrmentation was

[ therefore limited to mdes 1 and 2. W Source Range response times g were requested nor supplied.

ll l The NRC has requested that either the Power Range operability be E extended to modes 3, 4, and 5 or a response time for the Source Range trip be supplied to assure reactor protection in these Modes.

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, It is KG&E's position that this is a generic issue since Westinghouse has perfomed similar safety analyses for other plants and the 'Ibchnical I

specifications for these plants, and the Standard Technical Specifi--

cations, have no requirements for Source Range response time or Power

Range operability in Modes 3, 4, and 5. In order to ensure that the r solution to this question is carefully fomulated with full mder-s standing of all its implications and reprocussions, the question should

[ be resolved in an Owners Group form with participation by Westinghouse, the affected utilities, and the NRC.

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In the interini, KGE's recent preoperational testirg progran has per-

? formed Source Range response time testirg and the results obtained show 6 response times less than that required for the Power Range. This 7 envelopes the situation of concern since the Source Range trip occurs at

{ a lower neutron flux level.

In addition KGE will support the Westinghouse Owners Group's efforts to pursue this and other issues identified in NUREG 1024 with the NFC Staff .

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on a generic basis.

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8, CONTAINMENT SYSTEMS i

HYDROGEN MIXING SYSTEM LIMITING CONDITION FOR OPERATION 1

1 3.6.4.3 Two independent hydrogen mixing systems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTION:

lWith one independent hydrogen mixing system inoperable, restore the inoperable system to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

-SURVEILLANCE REQUIREMENTS 4.6.4.3 Each independent hydrogen mixing system shall be demonstra-ted OPERABLE:

a. At least once per 92 days on a STAGGERED TEST BASIS by t starting each non-operating system from the control room L and verifying that the system operates for at least 15 minutes.

! b. At least once per 18 months by verifying that on a Safety Injection test signal, the systems start in slow speed or, if operating, shif t to slow speed.

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3/4 6-33 JHR/bds/6all

i FINAL DMFT BASES 7

SPRAY ADDITIVE SYSTEM (Continued) 5 solution recirculated within containment after a LOCA. This pH band minimizes

the evolution of iodine and minimizes the effect of chloride and caustpic stress corrosion on mechanical systems and components. The contained solution f volume limitline discharge includes an or location allowance for solution other physical not usable because of tank characteristics. The educator flow test of 52 gpm with RWST water is equivalent to 40 gpm NaOH solution. These assumptions are consistent with the iodine removal efficiency assumed in the safety analyses.

' 3/4.6.2.3 CONTAINMENT COOLING SYSTEM g

The OPERABILITY of the Containment Cooling System ensures that: (1) the t

g containment air temperature will be maintained within limits during normal

= operation, and (2) adequate heat removal capacity is available when operated

{ in con, Junction with the Containment Spray Systems during post-LOCA conditions.

p The Containment Cooling System and the Containment Spray System are redundant to each other in providing post accident cooling of the containment atmosphere. As a result of this redundancy in cooling capaDility, the allowable out of-service time requirements for the Containment Cooling System have been i=

appropriately adjusted. However, the allowable out-of-service time require-ments for the Containment Spray System have been maintained consistent with i

that assigned other inoperable ESF equipment since the Containment Spray y System also pr.ovides a mech,anism for removing iodine from the containment i atmosphere.

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{ 3/4.6.3 CONTAINMENT ISOLATION VALVES

- The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the 5 event of a release of radioactive material to the containment atmosphere or g pressurization of tne containment and is consistent with the requirements of GDC54 thru 57 of Appendix A to 10 CFR Part 50. Containment isolation within i the time limits specified for those isolation valves designed to close auto-t matically ensures that the release of radioactive material to the environment s will be consistent with the assumptions used in the analyses for a LOCA. -

3/4.6.4 COMBUSTIBLE GAS CONTROL p The OPERABILITY of the equipment and systems required for the detection and control of hydrogen gas ensures that this equipment will be available to

' maintain the hydrogen concentration within containment below its flammable limit during post-LOCA conditions. Either recombiner unit (or the Purge

[ System) is capable of controlling the expected hydrogen generati'on associated f

with: (1) zirconium water reactions, (2) radiolytic decomposition of water, and (3) c:rros un of me fis wi;nin can.;.i..r.en.. D.a ... r: gen Farge Suosysts g discharges directly to the Emergency Exnaust System. . Operation of the Emergency L Exhaust System with the heaters operating for at least 10 continuous hours in a i 31-day period is sufficient to reduce the buildup of moisture on the adsorbers t and HEPA filters. These Hydrogen Control Systems are consistent with the

$ recommendations of Regulatory Guide 1.7, " Control of Combustible Gas Concen-trations in Containment Following a Loss-of-Coolant Accident," Revision 2, November 1978.

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N WOLF CREEK - UNIT 1 8 3/4 6-4 ,

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I A. The Hydrogen Mixing Systems are provided to easiure adequate mixing of the containment atmosphere following a LOCA. This mixing action will prevent localized accumulations of hydrogen from exceeding the flamable limit.

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e Specification 3/4.6.4.3 Page 3/4 6-33 Justification: '

l. Deletion of the f an flow rate from STS surveillance requirement 4.6.4.3.b is done for consistency with the containment air cooler surveillance requirement 4.6.2.3.b which has no air flow measure-ment requirements.

In addition, the H, Mixing Fans are two-speed f ans (full and one-half speed) . The -normal operating flow requirenents (full speed) were established based on a nonnal ventilation requirement of 85,000 cfm each. This produces a half-speed flow rate of 42,500 cfm.

The design _ hydrogen mixing requirements (half speed) were estab-lished based on maintaining an air exchange rate of 5 changes per hour for the containment volume below the operating level. This

~r esulted in a required flow rate of 12,500 cfm for each of two fans.

Therefore, since the required flow rate of 12,500 cfm is so much smaller than the actual flow rate of 42,500 cfm, it is not nec-essary to verify flow rates, only that the f ans are operating properly.

It should also be noted that the H mixing f ans post LOCA operation is supplemented by the exp ed containment post-LOCA air flow patterns. Both the containment coolers and the con-tainment sprays cool the containment atmosphere causing it' to drop to the lower cor.tainment elevations where the containment heat load and the H7 mixing f ans then cause it to rise to the upper regions of the containment.

JHR/bds/6a6 i

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ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3) Verifying the fuel transfer pump starts and transfers fuel from the storage system to the day tark, ts %o 4- voo - Lt ao LIcitb

4) Verifying the diesel starts from ambie t condition and accelerate f.o at least 514 rpm in less than or eq al to 12 seconds.* TJe' generator voltage and frequency shall 4000 _ 320 vcit g nd 60 + 1.2 Hz within 12 seconds

after the start signal. The diesel generator shall be started for this test by using one of the following signals:

a) Manual, or b) Simulated loss-of offsite power by itself, or c) Safety Injection test signal.

5) Verifying the generator is synchronized, loaded to greater than or equal to 6201 kW in less than or equal to 60 seconds,* operates with a load greater than or equal to 6201 kW for at least 60 minutes, and

6) Verifying the diesel generator is aligned to provide standby power to the associated emergency busses,

b. At least once per 31 days and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months by checking for and removing accumulated water from the day tanks;

c. At least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks;

d. By sampling new fuel oil in accordance with ASTM 04057 prior to addition to storage tanks and:

(1) By verifying in accordance with the tests specified in ASTM 0975-81 prior to addition to the storage tanks that the sample has:

(a) An API Gravity of within 0.3 degrees at 60 F or a specific gravity of within 0.0016 at 60/60 F, when compared to the supplier's certificate or an absolute specific gravity at 60/60*F of greater than or equal to 0.83 but less than or equal to 0.89 or an API gravity of greater than or equal to 27 degrees but less than or equal to 39 degrees;

These diesel generator starts from ambient conditions shall be performed only once per 184 days in these surveillance tests and all other engine starts for the purpose of this surveillance testing shall be preceded by an engine prelube period and/or other_ warmup procedures recommended'by the manufacturer so that the mechanical stress and wear on the diesel engine is minimizRd WOLF CREEK - UNIT 1 3/4 8-3

ELECTRICAL POWER SYSTEMS SURVEILLANCE REOUIREMENTS (Continued)

(b) A kinematic viscosity at 40 C of greater than or equal to 1.9 centistokes, but les.s than or equal to 4.1 centistokes, if gravity was not determined by comparison with the sup-plier's certification; (c) A flash point equal to or greater than 125 F; and (d) A clear and bright appearance with proper color when tested in accordance with ASTM 04176-82.

(2) By verifying within 30 days of obtaining the sample that the ~

other properties specified in Table 1 of ASTM 0975-81 are met when tested in accordance with ASTM 0975-81 except that the analysis for sulfur may be performed in accordance with AST D1552-79 or ASTM 02622-82.

e. At least once every 31 days by obtaining a sample of fuel oil in accordance with ASTM D2276-78, and verifying that total particulate contamination is less than 10 mg/ liter when Checked in accordance with ASTM 02276-78, Method A.

f. At least once car 15 men ns. cur; ; s =:::c e t.

a _, Suojec.in; ne ciesel :c an insoect'on in accercance c :-

croceceres ore:are ir. conjunc:icn with its manufactureds recommendations for tnis class of s.andby service,

2) Verifying the diesel generator capability to reject a load of greater than or_ -equal'.o 1352 kW (ESW pump) while maintaining voltage 4000 _,320 v ts anc frequency at 60 + 5.4 Hz, asuo ruso -aqo

3) Verifying tne aiese r rator capability to reject a load of 6201 kW without tripping. The generator voltage shall not exceed 4784 volts during and following the load rejection,

4) Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergization of the emergency busses and load shedding from the emergency busses, and b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto-connected shutdown loads through the shutdown sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and f equen f the emergency busses shall be maintained a 4000 -320- olts and 60 + 1.2 Hz during this test. q[g 4%

WOLF CREEK - UNIT 1 3/4 8-4

e ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

5) Verifying that on a Safety Injection test signal without loss-of-offsite power, the diesel generator starts on the auto start signal and operates on standby for greater than or equal to 5 minutes; and the offsite power source energizes the auto-

'onnected emergency (accident) load through t e t0CA-sqquencer.

The generator voltage and frequency shall be '000 ; 3 M \ volts

and 60 1 1.2 Hz within 12 seconds after the to-start st nal; the generr. tor steady-state generator voltag and frequency all be maintained within these limits during t q test; N 4 # 4so HW W 0 0

6) Simulating a loss-of offsite power in conjunction with a%Tety Injection test signal, and a) Verifying deenergization of the emergency busses and load shedding from the emergency busses; b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto connected emergency (accident) loads through the LOCA sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with emergency loads. After energization, the steady-state voltage and fyequency %

the emergency busses shall be maintained a[4000 ; 320 v 'ts and 60 1 1.2 Hz during this test; and eoww-no c) Verifying that all automatic diesel generator trips, except high jacket coolant temperature, engine overspeed, low IL %

oil pressure, high crankcase pressure, start failure relay, and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a Safety Injection Actuation signal.

7) Verifying the diesel generator operates for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

During the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of this test, the diesel generator shall be loaded to greater than or equal to 6821 kW and during the remaining 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of this test, the diesel generator shall be loaded to greater than or epc8TTtri kW. The generator voltage and frequency shall bp 1000-+-320- olts and 60 + 1.2 Hz,

- 3 Hz within 12 seconds after the start ignal; the steady-state 7eneqator voltage and fr quency sha 1 be maintained within unco t:6e Mao 40001320 volts and 60 1 1. z during th test. Within 5 minut W after completing s 24-hour test, erform Specifica-tion 4.8.1.1.2f.6)b)*;

4 tbo + 16e Wao v

If Specification 4.8.1.1.2f.6)b) is not satisfactorily completed, it is not necessary to repeat the preceding 24-hour test. Instead, the diesel generator may be operated at 6201 kW for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or until operating temperature has stabilized.

WOLF CREEK - UNIT 1 3/4 8-5

a g, b

REFUELING OPERATIONS FINAL BRAFT l

SURVEILLANCE REQUIREMENTS (Continued) 2)

Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Pcsition C.6.a of Regulatory Gyide 1.52, Revisison less than March 1978, for a methyl iodif l# penetration-of and -+ J, - o % .+ a u au W G- .

3) 5 me4y C;Na VerifyingYsystem flow rate of 9000 cfmMduring system operation when tested in accordance with ANSI N510-19 E 1980.

c.

After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 1%;

d. At least once per 18 months by: or epal 40 71

1) Verifying that the pressure drop across the com ined HEPA filters and charcoal adsorber banks is less than inches Water Gauge while operating the system at a flow rate of 9000 cfm( -1GD +3 -M

2) Verifying that on a%.a h Wat.)

5 p,. . a. f a . 3T M Gaseous Radioactivity-High I

test signal, the system automatically starts (unless already operating) and directs its exhaust flow through the HEPA filters and charcoal adsorber banks and isolates the normal fuel building exhaust flow to the auxiliary / fuel building exhaust fan; 3)

Verifying that the system maintains the Fuel Building at a negative pressure of greater than or equal to 1/4 inches Water Gauge and relative to the outside atmosphere during system operation;

4) Verifying that the heaters dissipate 37 2 3 kW when tested in accordance with ANSI N510-1975.

fe. After each complete or partial replacement of a HEPA filter bank, by I

verifying that the cleanup system satisfies the in place penetration gpc,E and bypass leakage testing acceptance criteria of less than 1% in g.,g accordance with ANSI N510-1975 for a 00P test aerosol while operating the system at a flow rate of 9000 cfm i 10%; and k

W ed , f.

After each complete or partial replacement of a charcoal adsorber

-p LeM

} bank, by verifying that the cleanup system satisfies the in place-l penetration and bypass leakage testing acceptance criteria cf less l ( than 1% in accordance with ANSI N510-1975 for a halogenated

< hydrocarbon refrigerant test gas while operating the system at a flow rate of 9000 cfm i 10%.

WOLF CREEK - UNIT 1 3/4 9-18

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R ML Mf5T 3/4.5 EMERGENCY CORE COOLING SYSTEMS BASES 3/4.5.1 ACCUMUltitf The OPERABILITY of each Reactor Coolant System (RCS) accumulator ensures that a sufficient volume of borated water will be immediately forced into the core through each of the cold legs in the event the RCS pressure falls below the pressure of the accumulators. This initial surge of water into the core provides the initial cooling mechanism during large RCS pipe ruptures.

The limits on accumulator volume, boron concentration and pressure ensure that the assumptions used for accumulator injection in the safety analysis are met.

The accumulator power operated isolation valves are considered to be

" operating bypasses" in the context of IEEE Std. 279-1971, which requires that bypasses of a protective function be removed automatically whenever permissive conditions are not met. In addition, as these accumulator isolation valves fail to meet single failure criteria, removal of power to the valves is required.

The limits for operation with an accumulator inoperable for any reason except an isolation valve closed minimizes the time exposure of the plant to a LOCA event occurring concurrent with failure of an additional accumulator which may result in unacceptable peak cladding temperatures. If a closed isolation valve cannot be immediately opened, the full capability of one accumulator is not available and prompt action is required to place the reactor in a mode where this capability is not required.

na reouirement to verify accumulator isolation valves shut with nm r removed from the ralve ep r2+nr when the preun*42 r i =vila ensures the accumlators will not infact s tor ano ca h a p e "ra transient when the Da20tc. Cuviant System is on solid plant pressure control. ~

3/4.5.2, 3/4.5.3, and 3/4.5.4 ECCS SUBSYSTEMS The OPERABILITY of two independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available in the event of a LOCA assuming the loss of one subsystem through any single failure consideration.

Either subsystem operating in conjuncticn with the accumulators is capable of supplying sufficient core cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double ended break of the largest RCS cold leg pipe downward. In addition, each ECCS subsystem provides long-term core cooling capability in the recirculation mode during the accident recovery period.

With the RCS temperature below 350'F, one OPERABLE ECCS subsystem is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

WOLF CREEK - UNIT 1 B 3/4 5-1 !

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ML20114B416

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Dear Mr. Denton:

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