ML20116J317

Application for Amend to License NPF-42,revising TS SR 4.2.1.1 to Eliminate Monitoring & Logging Requirements Not Applicable to Method of Axial Flux Difference Control Used at Plant

ML20116J317
Person / Time
Site:	Wolf Creek
Issue date:	11/05/1992
From:	Hagan R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20116J320	List: ML20116J317 ML20116J330
References
NA-92-0089, NA-92-89, NUDOCS 9211160130
Download: ML20116J317 (11)

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WOLF CREEK

' NUCLEAR OPERATING CORPORATION Robert C. Hagan Vke hnM Ndar Auwanu November 5, 1992-NA 92 J089 U. S. Nucleat Regulatory Comission ATTN Document. Control Desk Mail Station PI-137 Washington, D. C.

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Subject:

Docket No. 50-482: Proposed Revision to Technical Specification Surveillance Requireaents 4.2.1.1 for Axial Flux Difference Monitoring Gentlemen:

Enclosed is an application for amendmeat to Facility Operating Licenee No. NPF-42 for Wolf Creek _ Generating Station (WCGS), Unit No.-1.

This

, posed amendment would modify _ Torhnien1 Specification Surveillunce Requirement 4.2.1.1 to' eliminate monitoring and loce,ing requirements-that are not applicable to the method of axial flux difference control used at WCGS.

Attachments I through III provide the Safety Evaluation, Significant Has : ws Consideration Determination, and Environmental Impact Datermination supporting the requested chtnge.

Attachment IV provides the reviaed Technical SpecitAcation page. The proposed revision will be fully implemented within-30 days of forma! Nuclear Regulatory Commission approval.

In accordance with 10 CFR 50.01, a.. copy of this - application, with.

attachments, is being provided to the designated Kansas Stato Official.

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PDR ADOCK 05000482 P

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!I FO Box 411/ Bortsngtom KS 66839 / Phone (316) 364-8831 b

An Equal Opporturuty Employer WF/He< VET W

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'alA 92-0089' Page 2 cf 2

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If you have:any questions concerning this matter, please contact'me at'-

(316) '364-8831 Ext. ~4553 or Mr.

Tevin J.-

Moles of ;my. staff' at-(316) 364-8831 Ext. 4565.

Very tr'uly yours, gj dl 5 '

Robert C. Hagan

-Vice President Nuclear Assurance RCH/jra Attachments:

I - Safety Evaluation-II - Significar.t Hazards consideration Determination III - Envit inmental Impact Dete rmination IV

. Proposed Tecnnical Specification Changes cc G. W. Allen (KDHE), w/a

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A. T. tioveli (NRC), v/a J. L. Milhoan (NRC), w/a G. A. Pick (NRC), w/a W. D. Reuley (NRC), w/a '

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l STATE OF KANSAS

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1 SS COUNTY OF COFFEY s

Robert C.

Hap 9n, of lawful age, being first duly sworn upon oath saya that he is Vice n' resident Nucleat Assurance of Wolf Creek Nuclear Operating Corporation:

that he has read the foregoing docunent 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

orrect to the best. of his knowledge, information and belief.

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Robe /t C. Hagan

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Vic President jy

-Nuc ear Assirance 7

SUBSCRI. RED and sworn to tefore me this day of NovemM A992.

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4 Notary'Yublic Expiration Date,\\R oci.CIS -

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a Attachment I to NA 92-0089 P.ge-1 of 3 ATTACIIMENT I SAFETY EVALUATION f -

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Q, Attachment I to NA 92-0089 Page 2 of 3 SAFETY EVALUATION DESCRIPTION OF CHANGE This license amendment retuest proposes to revise Technical' Specification 3/4.2.1, " Axial Flux Difference," Surveillance Requirement 4.2.1.1 to eliminate reouirement 4.2.1.1 a.2) regarding monitoring the -

indicated Axial - Flur Difference (AFD) af ter restoring the AFD Monitor Alarm to OPERABLE status and to-change the requirements _for monitoring _

and logging indicated AFD when the AFD Monitar-Alarm is inoperable.

The proposed change would require monitoring and logging the indicated AFD once per hour for the entire period that the AFD Monitor Alarm is inoperable._ The pcesent requirement to menitor and log - the indicated AFD at 30-minute intervals after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be removed.

EVALUATION Wolf Creek.- Generating Station (WCGS) currently useso the Relaxed Axial -

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Offset Control (RAOC) method of axial power distribution control.

Use of RAOC was approved by - the NRC in Amendment No.

1. - dated April 22, 1986. to the WCGS operating license.

Prj ar to use of T.AOC. the method of axial power distribution employed was Con tant Axial Off set-Control (CAOC).

The CAOC method required tue AFD to be maintained within a target ba'id about a. target flux - dif ference.

Whenever AFD was outside' ' the target band, penalty time was accumulated at specified rates depending lupon the thermal power level.

The amount of penalty time: accumulated during:the previous 24-hour period was used to further restrict. plant operation

.until the AFD could be returned to within acceptable - operating limits. -

The penalty time. wa s normally comput ed automa tically by =the-plant

j computer.

1he plant -computer provided _.an.

essentially continuous-determination of penalty time, for tho. previous 124 hours0.00144 days <br />0.0344 hours <br />2.050265e-4 weeks <br />4.7182e-5 months <br /> ~ and provided ;

warnings to the plant operators via the AFD Monitori AJ arra.

The CAOC.

Technical Specification surveillance. re,uirements included provisions; to; l

manually monitor and log the indicated AFD during periods when the1AFD j

-Monitor Alarm-was inoperable or unable to. determine the penalty time for l

the previous 24 - hours.

.Ifl the AFD Monitor Alarm program ~ had = been j

stopped and. then -restarted, the accumulated 1 penalty _ time had _the4 y

potential of being inaccurate for the subsequent 24-hour: period.

Existing Surveillance Roquirement-

4.2.1.1 a. 2),

'which tequires j

monitoring the indicated AFD-at -least' once iper hour for the' first ;. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after restoring ~ the ~ AFD Monitor-Alarm to opersble ' status, :-is ' a j

vestige ' of the CAOC - surveillance ' requirement : thatl.was intended to-accumulate _ AFD ~ data during the : period that the process computer was_-

rebuilding.its_24-hour; data base.

Since the-RAOC method of-AFD cot;rol' d

does not employ a -penalty time - associated with a target land,~there is no need to manually; accumulate this-'information Laf ter the 4AFD MonitorL Alarm:is' returned to operable stetus...

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' to NA 92-0039-Page 3'of'3-Existing Surveillance Requirement 4.2.1.1 b., which applies when the AFD-Monitor Alarn -is inoperable, includes a provision to monitor and log' indicated AFD at least once per hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 30 minutes-thereafter.

There ' is no technical '. basis -for increasing the frequency of monitoring and logging after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The once-per-hour frequency applicable for tite first.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would continue to be adequate for detecting AFD velues that are approaching the limits of the _ allowed operational envelope.

Wolf Creek Nuclear. Operating Corporation (WCNOC) places high priority on-maintaining the AFD Monitor Alarm operable; therefore, the amount of time that monitoring : and

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logging will be required will be minimized.

CONCLUSIONS Based en the above evaluation, the proposed deletion of Surveillance-Requirement 4.2.1.1 a.2) is essentially-an administrative change to1the Technical -- Specifica tions since the requirement is nct required for 'a _-_

plant that 'tas implemented RAOC, In addition,- the removal-of the -increased -frequency- (once per 30 minutes) f o r, AFD monitoring and logging ' in Surveillance Requirement' 4.2.1.1 b. will result in a default frequency of once.per hour r$tch ic; adequate for AFD mc'11toring while the AFD Monitor Alarm is inoperable.

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Attachment II to NA 92-0089 Page 1 of 3 ATTACifMENT 11 SIGNIFICANT !!aZARDS CONS'.DERATION DETERMINATION mm.__--__

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R Attachment II to NA 92 0089 Page 2 of 3' SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION This proposed amendment has been reviewed per the otandards provided in 10 CFR 50.92. Each standard is discussed separately below.

Standard 1 - Involves a Sinnificant Increase in the Probabili.tv or Consequences of an Accident Previous 1v Evaluated.

The ptoposed r' val of the req'2irement for monitoring the AFD once per hour for the tirst 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after restoring the AFD honitor Al arm to operable status is essentially cdministrative fu nature.

The requirement is a vestige of a method of power distr'.bution contrai, the CAOC method, that is no longer used at WCGS.

Becruse this requirement is not part of the current power distribution control methodology, its deletion-will have no impact on the consequences of any accidents previously evaluated.

Also, the power distribution Technical Specifications aa intended to assure that the assumptions used in tran lent and accident analyses are satisfied should-an_ accident or transient occur; and the proposed changes do not involve plant modificatione or the imposition of new performance ?quirements on plant systems or components.

Therefore, changes to these Technical Specifications would have no impact on the probability-of occurrence of a previously evaluated accident.

The proposed removal of the 30-minute monitoring and' logging requirement after the first 24 - hours of operation with an inoperable AFD Monitor Alarm would not involve an increase-in the cor equences of an accident previously evaluated-because the monitoring and logging activity would still be required to be performed once per - hour.

Continuing the monitoring and logging functions on'an hourly schedule after the first-24 hours would continue to pravide the same assurance that power distribution limits were maintained in accordance with ' the accident analyses.

Therefore, the consequences of previously evaluated accidents would not be increased. Also, as noted in the previous paragraph, e

changes to the AFD Technical Specifications vould have no effect on the probability of occurrence of a previously evaluated' accident.

Standard II - Create tbc Possibility or a New or Different Kind of Acc ident. inom Any Previous 1v Evaluated.

The Technical Specification requirements for power distribution limits are intended to - assure that the assmaptions rsed-in the accident and transient analyses are satisfied should an accident er transient' occur.

These requirements are of a monitorirg nature, and corrective actions are specified if the monitoced conditions exceed established limits.

The proposed amendment does not involve design changes, hardware-mtdifications nor-chaages -- to the method by which any - safety-related -

plant system performs its safety function.

Therefore, changes to these.

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Attachment II to riA 92-0089 Page 3 of 3 i

Technical Specifications would not create ' the possibility of a new or-different accident from any previously evaluated.

Standard III - Involve a Sinnificant Reduction in the Marnin of Safety.

The proposed removal of the requirement to monitor the indicated 'AFD once per hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after resto-ing the AFD Monitor Alarm to operable status would not reduce a margin of-. safety because_ the-analyses that were performed in support of the implementation of RAOC at WCGS showed that the AFD limits under RAOC provide an acceptable margin of safety and, once the AFD Monitor - Alarm is operable, the plant operators will be warned if that margin is degraded.

The RAOL method oi' power distributi n control does not require 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of monitoring of indicated AFD in order to provide this warning.

An AFD Monitor Alarm that is oprable" in accordance with the Technical Specification definition la capable of performing its specified function and has all of its r.ece s sa ry support syr tenis. capable of providing their necessary fun:tions.

The proposed - removal of the 30-minute f requency -. f or monitoring and' logging indicated AFD af ter the first.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of. operation with an -

inoperable AFD Monitot Alarm would not result in a significant reduction of a marb n of s fety because the requirement to monitor and log on an i

hourly f requency could provide the - same margin to.saf ety. as available during the firs

>* hours.

A reduction in'the frequency of' monitoring indicated AFD would represent a decreast in the time nargin available to the - operator to prevent.AFD from approaching the RAOC limits: however,-

the decrease is not significant because the-margin available-during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, using the hourly frequency, would not be reduced.

Based on the above, the requested Tachnical-Specification changes do not

. involve -- a significant increase - in - the probability' or consequences of a :

previously ' evaluated ~ accident, create the possibility of-a new or

- different kind of accident, or involve-a significant reduction in - the margin of safety.

Therefore, the' requested license amendment does not involve a significant hazards consideration in accordance _-with 10 CFR-.

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Attachment-III to NA 92-0089 Page 1 of'2 ATTACIIMENT III l-ENVIRONMENTAL IMPACT DETEIGi1HATION t

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l Attachment III to NA 92-0089 Page 2 of 'i ENVIRONMENTA1. 1RPACT DETERMINATION This amendment request meets the criteria specified in 10 CFR 51.22(c)(9) as specified below:

(1) the amendment involves no significant hazards consideration.

As demonstrated in Attachment II, the proposed change-do not involve any significant hazards consideration.

(ii) there is to significant change in the types or significant Inc. esse in the amounts of any effluents that may be released of fsite.

The proposed cnanges do not involve generation or release of effluents from the plant.

The changes impt.t surveillance requirements for reactor po"er distribution used to assure the operation of the plant within its safety design basis.

Thnrefore, the proposed charges will have no offect on normal plant ef fluents and there will be no change in the types or amounts of any aftluents released offsite.

(11t) there is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes to surveillance requirements will have no effect on general levels cf radiation present in the plant; nor will additional quantities of tadioactive materials be generated as a result of the proposed changes. Therefore, there will be no increase in individual or cumulatise occupations 1 radiation exposure associated with this proposed change.

Based on the above, it is concluded that there will be no impact on the-environment tesulting fram this change.

The change meets the critetia specifi d in 10 CFR 51.22 for a categorical exclusion from the e

requirements of 10 C7R 51.22 relatise to specific environmental assessment by the Commission.

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