ML20126E217

Application for Amend to License NPF-42,deleting TS 4.8.1.1.2(i)(2) Re Electrical Power Sys to Avoid Duplication of TS 4.0.5 Which Requires Inservice Insp & Testing of ASME Code Class 1,2 & 3 Components

ML20126E217
Person / Time
Site:	Wolf Creek
Issue date:	12/22/1992
From:	Hagan R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20126E219	List: ML20126E217 ML20126E221
References
NA-92-0138, NA-92-138, NUDOCS 9212290059
Download: ML20126E217 (10)

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LF CREEK OPERATING C ENnICm Anurne December 22. 1992 NA 92-0138 U. S. Nuclear Regulatory Commission ATTN - Document Control Desk i Mail Station P1-137 #

Vashington, D. C. 20555

Subject:

Docket No. 50-4822. Revision to Technical Specification 4.8.1.1.2(i)(2) - Electrical Power Systems Gentlemen:

This letter transmits an application for amendment to Facility - Operating

-License No. NPF-42 for Wolf Creek Generating Station (WCGS), Unit No. 1. The license -amendment request proposes ; deletion of Technical' Specification' 4.8.1.1.2(1)(2) as it duplicates Technical Specification 4.0.5.

Technical Specification 4.0.5 requires inservice inspection and testing of ASME Code Class 1, 2, and 3 components in accordance with Section XI of the ASME Boiler and Pressute Vessel Code. Technical Specification 4.8.1.1.2(1)(2) currently requires a pressure test of those portions of the diesel fuel oil system designed _to Section III. subsection ND of the ASME Code. This_ pressure

. test is restricted to 110 percent of the syst.em design pressure, while Section XI of the ASME Code provides alternative testing requirements. The existing diesel fuel oil system includes buried tanks and piping that are design (d for-atmospheric pressure- and are not designedL for pressure testing- above atmospheric conditions (i.e., no isolation -valves on atmospheric vents).

Therefore, the alternative testing allowed-by Technical Specification 4.0.5 is

-appropriate for the existing system. Alternative testing for the tanks and associated piping includes-leak testing at hydrostatic head pressure-with the tanks-filled to design capacity.

The= existing _ draft NUREG-1431, " Standard Technical _._ Specifications ,

!~ Vestinghouse Plants" -reviewed by the Westinghouse Owners . Group does not contain an equival_ent _ Technical Specification 4.8.1.1.2(i)(2) . However, the-

--draft maintains.the Technical Specification-_4.0.5 section. This--confirms the.

unnecessary duplication created by the existing WCGS technical specifications in the subject area.

Attachment I provides - a description of -the proposed ' amendment along with a Safety Evaluation. -Attachment II provides _ the ;.Significant _ Hazards - _,

Concideration Determination. Attachment III provides the Environmental Impact Determination. The proposed changes to 1 the technical specifications tare provided in Attachment IV.

9212290059 921222 PDR ADOCK 05000482 .;

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PO. Box 411/ Burhngtort KS 66839 / Phone (316) 364-8831

- An Equat opportunity Employer M/F/HcNET ,

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l NA 92-0138 Page 2 of 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments is being provided to the designated Kansas State official. The proposed alternative test in planned for the sixth refueling outage which is scheduled to start in March 1993. This proposed revision to the VCGS technical specif1 cations will be fully implemented within 30 days of formal Nuclear Regulatory Congnission approval .

If you have any questions concerning this matter, please contact me at (316)364-8831 Ext. 4553 or Mr. Kevin J. Moles of my staff at Ext. 4565.

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Very truly yours,

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' Robert C. Hagan Vice President Nuclear Assurance RCll/ j ra Attachments: I - Safety Evaluation II - Significant llazards Consideration Determination III - Environmental Impact Determination IV - proposed Technical Specification Change cci G. W. Allen (KDriE) , w/a A. T. Howell (NRC), w/a J. L. M11hoan (NPC), w/a -

G. A. Pick (NRC), w,'a W. D. Rer*'ey (NRC), w/a

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. STATE OF KANSAS )

) SS COUNTY OF C0FFTY )

Robert C. Hagan, of lawful age, being first duly sworn upon oath. cays that. <

he in Vice President Nuclear Assurance of Wolf Creek Nuclear Operating-Corporations 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.

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By 5 (/0 / - , #~L Rop.rt'C. Hahan / '

Vice President - (;'-

Nuclear Assurance SUBSCRIBED and sworn to before me this M day of Ce4- , 1992.

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DENISE L LAWHORN Notary Public h0 TAW PUBUC STATE OF KANSAS

'C'Z ' My Appt Exp.

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Expiration Date i f 08 I UI' s n -_. _ __ _-

-Attachment I to NA 92-0138 Page 1 of 3 ATTACIMENT I SAFETY EVALUATION.

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-Attachment I to NA 92-0138 Page 2 of-3 Safety Evaluation Proposed Change The purpose of the proposed technical specification change is to delete E Section 4.8.1.1.2(1)(2) as it duplicates Section 4.0.5.

Background

Technical Specification 4.0.5 requires inservice inspection and testing of ASME Code Class 1, 2, and 3 componente in accordance with Section XI of the ASME Boller and Pressure Vessel Code. Technical Specification 4.8.1.1.2(i_)(2) _

currently requires a pressure test of those portions of the diesel fuel oili system designed to Section III, subsection,ND of the ASME Code. This pressure-test is restricted to 110 percent of the system design pressure, while Section-XI of the ASME Code provides for alternative testing requirements. The existing diesel fuel oil syster. includes buried tanks and piping that are designed for atmospheric pressu re and are not designed for pressure testing j above atmospheric conditions (i.e., no isolation valves-on atmospheric vents). N Therefore, the alternate testing -allowed by Technical Specification 4.0.5 "is i appropriate for the existing system. Alternate testing for the tanks and associated piping includes leak testing at hydrostatic head pressure.with the.

tank filled to design' capacity.

The Bases for Technical Specification 4.8.1.1.2(1)(2)- describes- the surveillance requirements for the diesel fuel' oil system as .being in.

accordance with Regulatory Guide 1.137, " Fuel Oil Systems for Standby Diesel Generators," Revision 1. Thia Regulatory Gul.de refers to ANSI N195-1976,

" Fuel Oil Systems for Standby Diesel Generators."- Section 7.3 of the7 ANSI- E standard states that the arrangement of the fuel oil system shall provide for Inservice inspection and testing in accordance with- ASME Section XI.

Therefore, the intent of -the surveillance per Technical -Specification 4.8.1.1.2(1)(2) is the same as Technical Specification 4.0.5, which is to meet ASME Section XI requirements.

Reason for the Proposed Change-The 10 year surveillance required by - Technical Specification 4.8.1.1.2(1)(2)  ;

has~been scheduled for the upcoming sixth' refueling outage.- In1 preparing to

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perform this surveillance it was identified that. the requirement for performing a 110 percent'presture test are not practicable-for portions.of the ,

diesel fuel oil system. It was also_ determined that-the-ASME Section XI basis i for. performing the test had - alternate test methods Esultable to c the existing I configuration at Wolf Creek Generating - Station' (WCGS) . - With both . Technical 4 Specification 4.8.1.1.2(1)(2) and 4.0,5 addressing surveillance requirements for portions of the diesel _ fuel- oil _ system, -it was decided to propose : a technical specification change to remove the duplication and allow flexibility, for'use of the base document requirements for both specifications.

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Attachment I to NA 92,0138-Page 3 of 3 Evaluation of Proposed Change The proposed technical specification change to delete Section 4.8.1.1.2(1)(2)~

would not result in'a reduction in safety since the - d'esel fuel oil system test per ASME Section XI would still be required by Technical Specification 4.0.5. The type.of test required by ASME Section XI is appropriate _ for tha WCGS design while'the current Technical Specification .+.8.1.1.2(1)(2) test-is ,

not practical._ Therefore, the proposed revision allows testing flexibility. s while maintaining the same . level of protection provided by- the original npectEicatLon.

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Attachment II to NA 92-0138-Page 1 of 2 ATTACID4ENT II SIGNIFICANT llAZARDS CONSIDERATION DETERMINATION i

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Attachment II to NA 92-0138 Page 2 of 2 Significant llazsrds Consideration Determination The proposed license amendment would delete Technical Specification 4.8.1.1.2(1)(2). This section duplicates the requirements in Technical Specification 4.0.5. The following sections discuss the proposed change under the three standards of 10 CFR 50.92.

Stanoard I - Involves a Significaur. Increase in the Probability or Consequences of an Accident Previously Evaluated.

The proposed. change would remove a duplication in the technical specifications _

and allow appropriate surveillance testing to be performed on the diesel fuel oil system. The revised testing requirement would not affect the probability or consequences of an accident previously analyzed as it maintains equivalent testing requirements.

Standard II - Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.

The proposed change does not alter the parameters of plant operation or equipment design. The change will-allow an appropriate surveillance test to be performed on the diesel fuel oil system. Therefore, the change would not create the possibility of a new or different kind of accident from any previously evaluated.

Standard III - Involve a Significant Reduction in the Margin of Safety The proposed change to allow an appropriate surveillance test on the diesel fuel oil system will . not have an adverse impact on the margin of safety as defined in the technical specifications. The alternate test is equivalent to the previously specified test. Therefore, the proposed change does not.

involve a significant reduction in the margin of safety.

Based on the above, it is concluded that the proposed technical specification change does not involve a significant hazard. _

Attachment III to NA 92-0138 Page 1 of 2 ATTACIIMENT III ENVIRONMENTAL IMPACT DETERMINATION

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P Attachment III to NA 92-0138 Page 2 of 2 e

~ F.nvironmental Impact Determination i

10 CFR 51.22(b) specifies *he criteria for categorical exclusions f rom the requirement for a specific environmental assessment per 10 ' CFR 51.21.- This-amendment request meets the criteria specified in 10. CFR 51.22(c)(9).

Specific criteria contained in this section are discussed below. {

(i) the amendment involves no significant hazards consideration As demonstrated in the Significant Hazards Consideration Determination in .

Attachment II, this proposed amendment does not involve any significant-hazards considerations.

(11; there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

This amendment involves no change to the f acility or operating procedures-which would cause an increase in the amounts of effluents or create new type-of effluents chat may be released offsite.

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

occupational radiation exposure The nature of the change is administrative and does not require additional exposure to personnel nor affect levels of radiation present. The proposed change does not result in significant individual or curulative occupational l radiation exposure.

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!' Based on the above it is concluded there vill be no impact on the environment resulting from this change r.d the change meets the criteria specified in 10

. CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21.

relative to specific environmental assessment by the Commission.

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