ML20117K715
| ML20117K715 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/05/1996 |
| From: | Muench R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ET-96-0063, ET-96-63, NUDOCS 9609120099 | |
| Download: ML20117K715 (3) | |
Text
._ __ _ _ _
i WfdLF CREEK NUCLEAR OPERATING CORPORATION Richard A. Muench Vice President Engineering September 5, 1996 i
ET 96-0063 U.
S. Nuclear Regulatory Commission l
ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555 I
l
Reference:
1)
Letter CO 95-0001 dated March 24, 1995 from l
R.
N. Johannes, to USNRC j
2)
Letter ET 95-0073 dated July 26, 1995 from R.
C. Hagan, to USNRC i
Subject:
Docket No. 50-482: Additional Information Concerning Revision to Technical Specification 3.5.1,
" Emergency l
Core Cooling Systems - Accumulators" Gentlemen:
I This letter submits additional information regarding the application for amendment submitted by Reference 1 and supplemented by Reference 2.
This additional information, contained in the attachment, was requested during discussions with Mr.
J.
C.
Stone, NRC Project Manager. for Wolf Creek Generating Station.
The information addresses the Nuclear Reactor Regulation (NRR) proposed three-tiered approach to risk-based technical specification allowed outage time (AOT) modifications.
A similar license amendment request was approved for the callaway plant on August 5,
1994 (Amendment 91).
This additional information associated with References 1 and 2 has no affect on the conclusions of the previous-Safety Evaluation, No Significant Hazards Consideration Determination, or Environmental Impact Determination.
If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4034, or Mr. Terry S. Morrill, at extension 8707.
l l
Ve trul yours, 9609120099 960905 PDR ADOCK 05000482 P
PDR Richar A. Muench RAM /jad i
l Attachment cc:
G.
W. Allen (KDHE), w/a l
L. J.
Callan (NRC), w/a i
W.
D.
Johnson (NRC), w/a J.
F.
Ringwald (NRC), w/a
[gC
(
J.
C. Stone (NRC), w/a f
l P.O. Dox 4111 Durhngton, KS 66839 i Phon 9: (316) 364 8831 i-l 3.sge'3,i t
g)
An Equal Opportunsty Employer M F HC' VET I
}
1 I
.6 l
STATE OF KANSAS
)
)
SS COUNTY OF COFFEY
)
Richard A. Muench, of lawful age, being-first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; i.
that he has read the foregoing document 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 correct to the best of his knowledge, information and belief, t
l By Richard /A. Muench l
Vice Pdsident Engineering l
SUBSCRIBED and sworn to before me this Eb day of
.$<p b 1996.
bwaLJE Yt bmL l
ANGELA E.WESSEL Notary Public Notmy Put4c Stateof Kansas I
My Appt. Empires C7/03/99 l
Expiration Date de,_z u J, / 99 9 c
,r 1
i i
l i
i l
\\
M 1
l l
I
/
e Attachment to ET 96-0063 Page 1 of 1 Additional Information to Support Risk-Based AOT Extension The Office of Nuclear Reactor Regulation (NRR) has proposed a three-tiered I
approach to risk-based technical specification allowed outage time (AOT) l modifications.
Provided below is Wolf Creek Nuclear Operating Corporation's i
(WCNOC) response to the three tier approach.
Tier 1:
The licensee must determine the acceptability of the change.
1 Probabilistic Risk Assessment (PRA) analysis must conclude that an acceptable change in Core Damage Frequency (CDF) exists if the proposed change were implemented.
i Responses As discussed in References 1 and 2, the effect on the plant CDF of l
the proposed change to the accumulator AOT was evaluated and j
l determined to be acceptable.
1 Tier 2:
The second tier is designed to provide reasonable assurance that i
l unacceptable plant equipment outage configurations do not occur l
l while an extended AOT exists.
Prior to entry into the AOT, the l
l status of key associated systems and trains should be reviewed for i
l safety significance.
l Responses Procedure AP 22C-003,
" Operational Risk Assessment Program,"
provides for a risk assessment of the weekly schedule.
The risk assessment considers maintenance and testing activities reflected in the schedule as well as reviewing the equipment out of service j
log, temporary modifications, and the operator work arounds, to determine their affect upon the ability to perform safe shutdown, l
accident mitigation or maintenance of commercial operation.
l Compensatory measures are identified for those preplanned or emergent activities determined to be risk significant.
l Prior to entry into an AOT activity, the status of key safety systems is reviewed by Operations personnel and the central work authority to ensure that the plant will not be placed in a risk I
l significant configuration.
Tier 3:
The third tier approach requires that an assessment of the overall j
impact on safety functions, as required by the proposed Maintenance Rule, be performed prior to performing maintenance activities, including the removal of any equipment from service.
1
Response
Prior to performing maintenance activities, an assessment of the overall impact on safety functions, as described above under tier l
2, is performed to ensure that the plant is not placed in a risk-significant configuration.
In addition, work controls and the l
organizations performing the work consider reliability, availability, and other performance criteria when making work scheduling decisions that affect plant, system, train or component
(
performance.
l l
t
-