ML20135D978

Application for Amend to License NPF-42,changing TS Table 3.3-3 to Correct Ref to Applicable Action Statement for Item 7.b,RWST Level - Low-Low Coincident W/Safety Injection

ML20135D978
Person / Time
Site:	Wolf Creek
Issue date:	12/03/1996
From:	Muench R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20135D980	List: ML20135D978 ML20135D991
References
ET-96-0075, ET-96-75, NUDOCS 9612100291
Download: ML20135D978 (13)

Text

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I W@,JLF CREEK NUCLEAR OPERATING CORPORATION 1

Richard A. Muench Vice President Engineering l

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December 3, 1996 ET 96-0075 U.

S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C.

20555

Reference:

1)

Letter ET 91-0047 dated March 1, 1991, from F. T. Rhodes, WCNOC, to the NRC 2)

NRC Letter dated March 29, 1991, from D. V. Pickett, i

NRC, to B. D. Withers, WCNOC

Subject:

Docket No.

50-482:

Revision to Technical Specification Table 3.3-3, Engineered Safety Features Actuation System Instrumentation Gentlemen:

Reference 1 transmitted an application for amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS).

This request proposed to revise Technical Specification Tables 3.3-1, 4.3-1, 3.3-3, 4.3-2, and associated Bases, to increase the surveillance test intervals and allowed cutage times for the analog channels of the Engineered Safety Features Actuation System (ESFAS).

This request was approved and issued by Reference 2 as Amendment No. 43 to Facility Operating License No. NPF-42 for WCdS.

We have identified a change to Technical Specification Table 3.3-3 that should j

have been included in that request.

However, the change was not marked on the I

appropriate technical specification page submitted with the request and was subsequently omitted from the amendment.

The purpose of this letter is to request this change be made to Technical Specification Table 3.3-3.

A detailed description of the requested change is provided in Attachment I.

This issue was i

discussed between Mr.

J.

Stone, Nuclear Regulatory Commission (NRC), and Mr.

S.

Wideman, Wolf Creek Nuclear Operating Corporation.

A Safety Evaluation is provided in Attachment I, and Attachment II provides a do i

l Significant Hazards Consideration Determir.ation.

Attachment III is the

\\i Environmental Impact Determination, and the marked-up technical specification

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page for this request is provided in Attachment IV.

ak 9612100291 961203 A

PDR ADOCK 05000482

/XV P

PDR I

l Qh PO. Box 411 i Burkngton, KS 66839 / PNne: (316) 364 8831 An Equal Opportunny Employer h T HC VET

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ET 96-00~/5 Page 2 of 2 In accordance with 10 CFR. 50.91, a copy of this revision to our origiral application, with attachments, is being provided to the designated Kansas State official.

This proposed revision to the WCGS Technical Specifications will be fully implemented within 60 days of fortnal NRC approval.

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 Very truly yours,

$N Richard A. Muench RAM /jad Attachments I

- Safety Evaluation II - No Significant Hazards Consideration Determination III - Environmental Impact Determination IV - Proposed Technical Specification Change cc:

V.

L. Cooper (KDHE), w/a L. J. Callan (NRC), w/a W. D. Johnson (NRC), w/a J.

F. Ringwald (NRC), w/a J.

C. Stone (NRC), w/a

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STATE OF KANSAS

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COtBITY OF COFFEY

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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; 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 f

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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Richard A. Mu'ench i

Vice President Engineering i

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i SUBSCRIBED and sworn to before me this

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day of Ace.

, 1996.

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ANGELA E.WESSEL Notary p lic NotaryPublic Stateof Kansas My Appt. Expires d'//01/ 9 */

Expiration Date

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Attachm:nt I to ET 96-0075 Pago 1 of 4 ATTACHMENT I SAFETY EVALUATION

Attachm2nt I to ET 96-0075 Pcga 2 of 4 Safety Evaluation Proposed Change This license amendment request proposes to revise the Wolf Creek Generating Station (WCGS)

Technical Specifications to correct a reference to the applicable Action Statement for Item 7.b.,

RWST Level - Low-Low Coincident with safety Injection, in Technical Specification Table 3.3-3, Engineered Safety Features Actuation System Instrumentation.

Specifically, this item currently refers to Action 16, but should refer to Action 28.

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Background

On March 1,

1991, WCNOC submitted an application for amendment to revise Technical Specification Tables 3.3-1, 4.3-1, 3.3-3, 4.3-2, and associated Bases, to increase the surveillance test intervals, allowed outage times, and associated action statements for the analog channels of the Engineered Safety Features Actuation System (ESFAS).

The proposed changes also increased the

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allowed outage times for the ESFAS actuation logic and actuation relays of the Solid State Protection System. The proposed changes were based on WCAP-10271, its supplements, and NRC approvals issued in a Safety Evaluation Report (SER) dated February 22, 1989, for WCAP-10271 Supplement 2 and WCAP-10271 Supplement 2,

Revision 1,

ar.d a supplemental SER dated April 30, 1990, for WCAP-10271 Supplement 2,

Revision 1.

This request was subsequently approved by the NRC and issued as Amendment 43 to Facility Operating License No NPF-42 for WCGS.

One of the changes approved in Amendment 43 was the addition of new Action Statement 28 to Table 3.3-3.

This action statement provides for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place an inoperable channel in the tripped condition and increases the time an inoperable channel may be bypassed, to allow surveillance testing of other channels, from 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, consistent with the previously approved technical specifications for the Reactor Protection System and with WCAP-10271, Supplement 2, Revision 1.

Attachment IV of our March 1,

1991, submittal, provided technical specification pages marked up to show that new Action Statement 28 was applicable to several of the functional units listed in Table 3.3-3.

This action was also discussed in Attachment I of our March 1, 1991, submittal, as being applicable to Item 7 b.,

RWST Level - Low-Low Coincident with Safety Injection, of Table 3.3-3.

However, this change was inadvertently not marked on the appropriate page in Attachment IV of that submittal, and subsequently was not included in Amendment 43.

Evaluation As indicated above, one of the changes discussed in Attachment I of the March 1,

1991, submittal, was replacing Action Statement 16 with new Action Statement 28 for Item 7.b.

in Table 3.3-3.

As discussed in the March 1,

1991, submittal, with the exception of the containment pressure channels for containment spray actuation and Phase B containment isolation, WCGS does not have the capability to test, on a routine basis, an analog instrumentation

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Attachment I to ET 96-0075 Page 3 of 4 i

channel with the channel in a bypass condition.

Thus, the Table 3.3-3 Item 7.b. channels do not have the design for operation or testing in bypass needed l

for Action Statement 16 to be applicable.

Consistent with the previously approved technical specifications for the Reactor Protection System and with j

WCAP-10271, Supplement 2,

Revision 1, Action Statement 28 was added in WCGS I

Technical Specification Amendment 43 to permit the bypassing of an inoperable l

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channel for up to four hours in order to allow performance of ACOTs on other j

operable channels of the same functional unit.

This provision would apply in a

cases where a failed channel can be taken out of the test position (in which a j

channel trip. is forced) and returned to operation for a limited time an a j

condition which precludes a channel trip.

Due to its failed nature, the

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channel could not be assumed to be operable (until returned to a tripped condition) and would, therefore, be considered to be in a state of bypass.

Changing the Action Statement reference for Item 7.b.

in Table 3.3-3 from 16

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to 28 would limit the duration that a channel could be inoperable or be in f

l test with its bistable tripped.

This would reduce the probability of an automatic switchover from the RWST to an empty containment sump occurring

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while an RWST level channel was inoperable or was being tested with its i

i bistable tripped, and an inadvertent safety injection signal were to occur concurrent with a single failure of a second RWST level channel.

a Increased AOT for surveillance testing and increased STI for the ACOT of i

analog channels of Functional Unit 7.b was not included in the generic Technical Specification Optimization Program as discussed in WCAP-10271, Supplement 2, Revision 1.

Therefore, a separate, qualitative evaluation was performed for this item.

This evaluation demonstrates that the unavailability j

and risk:= associated with increased AOT and STIs for this functional unit is equivalent to, or less than, those of other functional units included in WCAP-l 10271. This evaluation is summarized below.

j Actuation of the automatic switchover from the Refueling Water Storage Tank j

(RWST) to containment sump occurs when the RWST Level Low-Low signal is j

i received coincident with a Safety Injection Signal (SIS).

By comparison of circuit design, it can be concluded that the unavailability of the two-of-four i

logic circuit for the RWST Level Low-Low signal is similar to that of the reactor trip signals developed by either the Overpower Delta-Temperature (OPDT) or Overtemperature Delta-Temperature (OTDT) signal. As demonstrated in

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WCAP-10271, Supplement 2, Revision 1, the unavailability of the OPDT and OTDT

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trip signals (and, by comparison, the unavailability of the RWST Level Low-Low j

signal) is generally an order of magnitude less than the unavailability j

calculated for the SIS.

Since automatic switchover from the RWST to I

containment sump occurs only on RWST Level Low-Low coincident with an SIS, the I

unavailability' calculated for the SIS dominates the unavailability for this function.

Use of the proposed optimized ESFAS technical specifications has i

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been shown not to result in any significant increase in SIS unavailability and to cause no significant increase in risk to the public.

Therefore, any i

increase in unavailability of the automatic switchover from the RW3T to z

j containment sump resulting from implementation of the proposed technical j

specifications is acceptable, since it is clearly dominated by the previously e

reviewed and approved SIS unavailability.

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At,tachment I to ET 96-0075 Page 4 of 4 Based on the above discussions and the no significant hazards consideration determination presented in Attachment II, the proposed change does not i

increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report; or create a possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report; 3r reduce the margin of safety as defined in the basis for any technic..! specification.

Therefore, the proposed change does not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.

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Attachm:nt II to ET 96-0075 Prga 1 of 3 4

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ATTACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 4

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Attachment II to ET 9A 0075 i

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t No Significant Hazards C asideration Determination i

This license amendment request proposes to revise the Wolf Creek Generating Station (WCGS)

Technical Specifications to correct a reference to the applicable Action Statement for Item 7.b.,

RWST Level - Low-Low Coincident with Safety Injection, in Technical Specification Table 3.3-3, Engineered Safety Features Actuation System Instrumentation.

Specifically, this item currently refers to Action 16, but shoulc' refer to Action 28.

Standard I - Involve a

Significant Increase in the Probability or Consequences of an Accident Previously Evaluated Changing the reference from Action Statement 16 to Action Statement 28 for Functional Unit 7.b.

of Table 3.3-3 will reduce the probability for an automatic switchover from the RWST to an empty containment sump to occur, while an RWST level channel is inoperable or is being tested with its bistable tripped, should an inadvertent safety injection signal occur concurrent with a single failure of a second RWST level channel.

The design of these channels does not allow for operation or testing in bypass, so Action Statement 16 is not applicable.

Changing to Action Statement 28 will limit the duration that a channel could be inoperable or be in test with its bistable bypassed.

This

. change does not involve any design changes or hardware modifications, and does not introduce any new potential accident initiating conditions.

The increase in allowed outage time for this item was evaluated and the associated unavailability and risk was shown to be equivalent to, or less than, that of other functional units evaluated in WCAP-10271, Supplement 2,

Revision 1.

Therefore, this preposed change does not increase the probability of any J

accident previously evaluated.

Scandard II - Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed change does not result in any hardware changes and does not result in a change in the manner in which the ESFAS provides plant protection.

This change does not alter the functioning of the ESFAS.

Rather, the likelihood or probability of the ESFAS functioning properly is affected as described above.

This change will not change the method by which any safety-related system performs its function.

Therefore, thia proposed change will 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 This proposed change will not result in a significant reduction in the margin of safety defined for any technical specification since it does not alter the manner in which safety limits, limiting safety system settings, or limiting conditions for operation are determined.

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i Atgachment II to ET 96-0075 Page 3 of 3 l

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l Based on the above discussions, it has been determined that the requested technical specification revision does not involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; or create the possibility of a new or different kind of accident or condition over previous evaluations; or involve a significant reduction in a margin of safety.

The requested license amendment does not involve a significant hazards consideration.

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AtAcchm:nt III to ET 96-0075 PegD 1 of 2 l

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ATTACNMENT III ENVIRONMENTAL IMPACT DETERMINATION i

i A$tachmsnt III to ET 96-0075 Paga 2 of 2 g

Environmental Impact Determination 10 CFR 51. 22 (b) specifies the criteria for categorical exclusions from the

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requirement for a specific environmental assessment per 10 CFR 51.21.

This l

amendment request meets the criteria specified in 10 CFR 51.22 (c) (9) as 4

specified below (1) the amendment involves no significant hazards consideration As demonstrated in Attachment II, the proposed change does not involve any

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significant hazards consideration.

(ii) there is no significant change in the types or significa"J., increase in I

the amounts of any effluents that may be released offsite i

The proposed change does not involve a change to the f acility or operating procedures that would cause an increase in the amounts of effluents or create new types of effluents.

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

occupational radiation exposure 1

The proposed change does not create additional exposure to personnel nor affect levels of radiation present. Also, the proposed change does not.Tesult in any increase in individual or cumulative occupational radiation exposure.

i Based on the above it is concluded that there will be no impact on the environment resulting from this change and the change meets the criteria i

specified it. 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission.

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Ay,techmant IV to ET 96-0075 Pign 1 of 2 ATTACHMENT IV PROPOSED TECHNICAL SPECIFICATION CHANGES a