ML20141N191

Application for Amend to License NPF-42,revising Tech Specs to Allow one-time Only Deferment of Type C Local Leak Rate Testing for Valves Delineated in Table 4.6.1.2-1 Until 860713

ML20141N191
Person / Time
Site:	Wolf Creek
Issue date:	02/26/1986
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20141N192	List: ML20141N191 ML20141N197
References
KMLNRC-86-033, KMLNRC-86-33, NUDOCS 8603040467
Download: ML20141N191 (4)

Text

.

KANSAS GAS AND ELECTRIC COMPANY TPE ELECTFWC COMPANY GLENN L AOESTER wCEPet00t%Y-mucLtaa February 26, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Cmmission Washington, D.C. 20555 KMLNRC 86-033 Re: Docket No. STN 50-482 Ref: 1) KMIRRC 86-007, dated 1/20/86, from GLKoester, KG&E to HRDenton, NRC;

2) KMINRC 86-008, dated 1/20/86, from GLKoester, KG&E to HRDenton, NRC Subj: Supp1miental Information and Modification of Proposed Revision to Technical Specification 4.6.1.2

Dear Mr. Denton:

The purpose of this letter is to provide supplemental information requested by the staff and to modify the proposed Technical Specification changes and requested exmption frm the requirements of 10 CFR 50, Appendix J, Section III.D.3 provided in the References. Reference 1 requested a revision to the Wolf Creek Generating Station, Unit No. 1, Technical Specifications to allow an extension of the testing interval specified in 10 CFR 50, Appendix J, Section III.D.3. Reference 2 requested a tmporary exemption to the requirments of 10 CFR 50, Appendix J, Section III.D.3.

Penetrations identical in configuration and utilizing identical components to those identified in the References have been successfully tested at the Callaway Plant which has been in cmmercial operation for approximately one year. These penetrations were successfully tested during both the preoperational testing program and subsequent tests to fulfill the periodic requirmients of 10 CFR 50, Appendix J, Section III.D.3. During the subsequent tests, these penetrations tested successfully without any rework l or repair. It should be noted that the analyses provided by the References  ;

assumed that valve leakage existed. The conclusion, that no significant hazard existed, was reached assming that leakage through these penetraitons was present.

As stated in Reference 2, the Cmmission has provided that special ciremstances must be present for an exmption request to be considered.

They have further provided that special ciremstances exist when, "The I exmption would provide only tmporary relief from the applicable regulation and the Licensee or applicant has made good faith efforts to comply with the 8603040467 860226 PDR P ADOCK 05000482 PDR ho I1 201 N. Market - Wichita, Kansas - Mail Address: RO. Box 208 l Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451

Mr. H.R. Denton KMLNRC 86-033 Page 2 February 26, 1986 regulation;". Initial local leak rate testing (LLRT) was done in parallel with the preoperational testing program at Wolf Creek Generating Station.

This allowed all required LLRT's to be current at the time of License issuance and therefore fuel loading and unit startup could begin promptly without the delay that performing nunerous LLRT's would have causa3.

It is generally not advantageous to perform surveillances or tests at intervals ~much shorter than required. This results in unnecessarily frequent operation of equipment and unnecessary radiation exposure to workers with no recognized concurrent gain in operational safety. Since initially entering Mode 3 on April 26, 1985 Wolf Creek Generating Station has not re-entered Mode 4. Kansas Gas and Electric Company (KG&E) believes that there has not been an outage of sufficient duration and appropriate plant conditions to perform the LLRT's delineated in the References, within-a time frame reasonably close to the required testing interval.

Contrary to the operational history of Wolf Creek Generating Station, industry experience indicates that an outage of sufficient duration and appropriate plant conditions to perform testing of this type is likely to occur during unit operation in Cycle 1. KG&E believes that a " .. . good faith effort to canply with the regulation;" has been made, but that the exenplary performance of the unit has prevented the tests from being performed.

Kansas Gas and Electric Company requests that the previous subnittals be revised to allow a one-time only deferment of the Type C local leak rate testing for the valves delineated in Table 4.6.1.2-1 until July 13, 1986.

'Ihe proposed changes to the Wolf Creek Generating Station, Unit No. 1, Technical Specifications are provided as an attachnent to this letter.

Testing of the additional valves mentioned in the References will be completed by the required due date associated with each valve. Valves BG-V135 and BG-HV8100, associated with penetration P-24, will be tested safely at Power Operation through the use of a tenporary system modification rather than the normal surveillance procedure.

. At the present time KG&E desires to keep Wolf Creek Generating Station on line to support systen power needs. Tenporary deferment of these tests will allow KG&E to take Wolf Creek Generating Station off-line at a time consistent with system need for power and the Wolf Creek Generating Station Owner's overall program of power managenent.  ;

The conclusions of the Safety Analysis and Significant Hazards Consideration I provided by the References are still wholly valid and correct. Based on the l l

l l

4 a

Mr. H.R. Denton KMLNRC 86-033 Page 3 February 26, 1986 technical analyses provided by the references and the supplanental information provided herein KG&E requests that an exenption to the requirenents of 10 CFR 50, Apperx3ix J,Section III.D.3, and the Technical Specification revisions discussed above be granted by the Nuclear Regulatory Comnission. If you have any questions concerning this matter please contact me or Mr. O. L. Maynard of my staff.

Very truly yours

+1 (( tb b' r L/

Glenn L. Koester Vice President - Nuclear GLK:see Attachnent cc: PO'Connor (2)

JCumnins GAllen EJohnson i

4 4

ATTACEMENT

'IO KMLNRC 86-033 l

l l