ML20141H943
| ML20141H943 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/23/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20141H941 | List: |
| References | |
| GL-91-08, GL-91-8, NUDOCS 9708040115 | |
| Download: ML20141H943 (5) | |
Text
- 44 y
UNITED STATES g
j NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20066 4001 o
.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.108 TO FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK NUCLEAR OPERATING CORPOPATION WOLF CREEK GENERATING STATION DOCKET N0. 50-482
1.0 INTRODUCTION
By letter dated February 17. 1997. Wolf Creek Nuclear Operating Corporation (the licensee) requested changes to the Technical Specifications (Appendix A to Facility Operating License No. NPF-42) for the Wolf Creek Generating Station (WCGS). The proposed changes would move Technical Specification (TS)
Table 3.6-1. " Containment Isolation Valves" to WCGS procedures which are subject to-the change control provisions in the Administrative Controls Section of the WCGS TS.
The movement of this table would require revision of Definition 1.7. " Containment Integrity." TS 3/4.6.1. " Containment Integrity."
and TS 3/4.6.3 " Containment Isolation Valves" to delete reference to Table 3.6-1.
These changes are in accordance with the guidance provided in Generic Letter (GL) 91-08. " Removal of Component Lists from Technical Specifications."
dated May 6. 1991.
Bases Section 3/4.6.3 will also be revised in accordance with the guidance provided in GL 91-08.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act of 1954, as amended (the Act) requires applicants for nuclear power plant operating licenses to include technical specifications as part of the license. The Commission's regulatory requirements related to the content of technical specifications are set forth in 10 CFR 50.36. That regulation requires that the technical specifications include items in five specific categories. including (1) safety limits, limiting safety system settings and limiting control settings: (2) limiting conditions for operation: (3) surveillance requirements: (4) design features:
and (5) administrative controls. The regulation does not specify the particular requirements to be included in the technical specifications.
The Commission, however, provided guidance for technical specification contents in its " Final Policy Statement on Technical S)ecification Improvements for Nuclear Power Reactors," which was pu]l1shed in the Federal Reaister at 58 FR 39132 (July 22, 1993). The Commission indicated therein that compliance with its Final Policy Statement satisfies Section 182a of the Act.
Criteria for the content of technical specifications were subsequently incorporated into 10 CFR 50.36 cf. 60 FR 36953 (July 19. 1995).
In particular the Commission indicated that certain items could be relocated 9700040115 970723 PDR ADOCK 05000402 P
PDR 1
J
- from the technical specifications to licensee-controlled documents. consistent i
with the standard enunciated in Portland General Electric Co. (Trojan Nuclear Plant). ALAB-531. 9 NRC 263. 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Boird indicated that " technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate l
threat to the public health and safety."
The four criteria defined by 10 CFR 50.36 for determining whether a particular matter is required to be included in the technical specification limiting conditions for operation are as follows:
(1)
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary:
(2) a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier:
(3) a structure, system. or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier:
(4) a structure, system or component which operating experience or 3robabilistic risk assessment has shown to be significant to public lealth and safety.
Existing technical specification requirements which fall within or satisfy any of the above criteria must be retained in the Technical Specifications: those requirements which do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.
3.0 _ EVALUATION The licensee has proposed the removal of Table 3.6-1. " Containment Isolation Valves." from the TS to WCGS plant procedures.
With the removal of this Table from the TS. the licensee has proposed the following changes:
e The statement of th'e Limiting Condition for Operation (LCO) under TS 3.6.3 would include:
Each containment isolation valve shall be OPERABLE.
definition of containment integrity (1.7). TS 4.6.1.la, and TS t
3.1 through 4.6.3.3 would be changed to remove all references to Table 3.6-1.
1
' e The following footnote to LC0 3.6.3 has been proposed:
Locked or sealed closed valves may be opened on an intermittent basis under administrative control.
o The definition of containment integrity and TS 4.6.1.la would now refer to TS 3.6.3 for the exception that is now contained in a footnote to the
)
LC0 rather than Table 3.6-1, as discussed above.
With the removal of the i
reference to Table 3.6-1, the licensee has proposed to state this-exception as:
...except for valves that are open under administrative control as permitted by Specification 3.6.3.
j e The surveillance requirements of TS 4,6.3.1 through 4.6.3.3 would be revised to state "Each power-operated or automatic containment isolation valve shall..." rather than stating the requirements in relation to the valves specified in Table 3.6-1.
e in order to model the TS after the guidance in GL 91-08, the following statement has been added as ACTION e to the LCO for TS 3.6.3:
e.
The provisions of Specification 3.0.4 do not apply.
1 The movement of Table 3.6-1 would not alter the limiting conditions for operation. surveillance requirements, or action statements of the TS associated with the containment (i.e.. TS 3/4.6.1 " Containment Integrity." and TS 3/4.6.3 " Containment Isolation Valves").
Generic letter 91-08 dated May 6. 1991, provided guidance to licensees on the removal of component lists from plant TS and on the placement of these lists into plant procedures which are subject to the change control provisions specified in the TS..
The movement of component lists to plant-controlled documents allows for timely updates of the lists without the formal requirement of a TS amendment.
The removal of Table 3.6-1 from the TS to administratively controlled procedures is editorial in nature and does not result in any physical change to the plant.
In accordance with the provisions of GL 91-08. which allow lists removed from the TS to be relocated to controlled documents. Table 3.6-1 will be placed in plant procedures.
Any changes to the plant procedures would be performed in accordance with the TS. Section 6. Administrative Controls, which provides a process similar to 10 CFR 50.59.
In addition, the Updated Safety Analysis Report (USAR) currently contains a list of containment isolation valves, including valve closure times, in Figure 6.2.4-1 and will be maintained.
Thus, any change to the containment isolation valve list would constitute a change to the facility, and would be subject to the provisions of 10 CFR 50.59.
O If the licensee determines from the 50.59 process that an unreviewed safety question resulting from a change would exist, due to either (1) an increase in the probability or consequences of accidents or malfunctions of ecuipment important to safety. (2) the creation of a possibility of an accicent or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety. NRC ap]roval via license amendment would be required prior to implementation of the clange.
The licensee has proposed TS changes that reflect the information previously located in TS Table 3.6.1 and these changes are consistent with the guidance provided in GL 91-08.
In addition. the licensee has provided an updated copy of the Bases Section of TS 3.6.3 that addresses appropriate considerations for opening locked or sealed closed valves on an intermittent basis.
Finally, the licensee has confirmed that component lists removed from the TS have been updated to identify all components for which the TS requirements apply.
These lists are located in controlled plant procedures and are currently in the USAR. Figure 6.2.4-1.
The Limiting Conditions for Operation (LCO) associated with containment integrity are being retained in the TS.
Therefore, the operability requirements for the containment isolation valves has not changed.
Only the list of valves is being relocated, which does not meet any of the four criteria to be retained in the TS as defined by 10 CFR 50.36.
On the basis of its review on this matter, the staff finds that the proposed changes to the TS for the Wolf Creek Generating Station are changes that do not alter the requirements set forth in the ex~ist.ing TS. However, the applicability of the operability requirements will extend to all containment isolation valves as noted in this evaluation.
These changes will allow the licensee to make corrections and updates to the list of components for which these TS requirements apply under the provisions that control changes to plant procedures as specified in the Administrative Controls Section of the TS.
Therefore, the staff finds that the proposed TS changes are acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Kansas State Official was notified of the proposed issuance of the amendment.
The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types.
of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no I
o '.
l
. 5-l i
l public comment on such finding (62 FR 19838). Accordingly, the amendment i
meets the eligibility criteria for categorical exclusion set forth in 10 CFR l
51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of I
l the amendment.
i 6.0- CONCLUSION l
l The Commission has concluded, based on the considerations discussed above.
J L
that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation-in the proposed manner (2) such activities will be conducted in compliance with the Commission's regulations, and-(3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
J. Stone C. Lauron l
Date:
July 23, 1997 l
l l
l l
i 4
w s.
--.y.i.
7 y
.