ML20150F328

Application for Amend to License NPF-42,revising Tech Specs Re ESFAS Instrumentation.Fee Paid

ML20150F328
Person / Time
Site:	Wolf Creek
Issue date:	07/06/1988
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20150F332	List: ML20150F328 ML20150F333
References
WM-88-0180, WM-88-180, NUDOCS 8807180239
Download: ML20150F328 (9)

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[N WQLF CREEK NUCLEAR OPERATING CORPORATION  !

Bart D. Withers Preeksent and Chief Execuevo officer Jt::y 6,1988 WM 88-018C 1

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Subject:

Docket No. 50-482: Revision to Technical Specification Tables 3.3-3 and 4.3 Engineered Safety Features Actuation System Instrumentation Gentlemen:

The purpose of this letter is to transmit an application for amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS)

Unit No. 1. This license amendment request proposes revising Technical Specification Table 3.3-3 and 4.3-2 which address Engineered Safety Features Actuation System-Instrumentation. This amendment request removes the MODE 2 applicability requirements from TABLE 3.3-3 Functional Unit 6.g'and TABLE 4.3-2 Functional Unit 6.g, "Trip of All Main Feedwater Pumps - Start Motor Driven Pumps'.

A complete Safety Evaluation and No Significant Hazards Consideration determination are provided as Attachments I and II respectively. The proposed changes to the Technical Specifications are provided as Attachment III.

In accordance with 10 CFR 50.91, a copy of this application, with attachments is being provided to the designated Kansas state official.

Enclosed is a check (No. 1877) for the $150.00 application fee required by 10 CFR 170.21.

The proposed revision to the Wolf Creek Generating Station Technical I Specifications will be fully implemented within 30 days of formal Nuclear Regulatory Commission approval.

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A A yid RO. Box 411/ Burtington, KS 66639 I Phone: (316) 364 8831 \

An Equal Oppxanty Employer IA0HcNET 8807180239 880706 PDR ADOCK 05000482 P ._P D_C_ , _ _ _ _ _ _ _ _

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WM 88-0180 Page 2.of. 2-Ju!.y 6, 1988 If you h' ave any questions concerning this matter, please contact me or'O. L.

Maynard of my staff.

Very truly.yours, e

Bart E. Withers President.and Chief Executive Officer BDW/jad Encic,sure Att.achments: I - Safety Evaluation II - Addressing the Standards in 10 CFR 50.92' III - Proposed Technical Specification Change cci G. W.' Allen (KDHE), w/a B. L. Bartlett (NRC), w/a D .- D. Chamberlain (NRC), w/a D. Martin -(NRC), w/a

.. W. O'Connor (NRC), w/a (2)

STATE'0P KANSAS ).

) SS COUNTY OP COPPEY )

-Bart D. Withers, of lawful age, being first duly sworn upon oath says that he is President and Chief Executive Officer 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 1 i Corporation ~w ith 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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Bart D. Withers President and Chief Executive Officer l-l l- SUBSCRIBED and sworn to before me this d' day of , 1988.

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.< , [c - . Expiration Date hM M, /9 f0 by . f

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e ATTACHMENT I SAFETY EVALUATION

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-e-Attachment I to WM 88-0180 Page 1 of 3

' July 6 , 1988 SAFETY EVALUATION DESCRIPTION OF PROPOSED AMENDMENT This proposed amendment revises Wolf Creek Generating Station (WCGS), Unit No.

st 1 Technical Specification Tables 3.3-3 and 4.3-2, _ which address the Engineered Safkty Features Actuation System Instrumentation. This amendment request removes the MODE 2 applicability requirements from TABLE 3.3-3 Functional Unit 6 5 and TABLE 4.3-2 Functional Unit 6.g. "Trip of All Main Feedwater Pumps - Start Motor Driven Pumps'.

REASON FOR PROPOSED AMENIHENT During noruml operation in MODE 2, the steam generators are normally being fed by either the startup motor driven feedwater pump or the auxiliary feedwater pumps. A turbine driven main feedwater Pump (TDMFP) is not started until the reactor is at approximately 22 power and preparations are being made to start the main turbine generator. Once a TDMFP is placed in service, reactor power is then increased above 5% into MODE 1, and the main-turbine is rolled up to speed.

When the plant is being shutdown, the main turbine generator is taken off line, reactor power is dropped below 5% (entering MODE 2) to approximately 22, the startup motor driven feedwater pump is placed in service, the last TDMFP is taken out of service and then the Reactor Operator inserts the control rods and lowers the plant into MODE 3.

The problem is that at least one TDMFPs must be reset (i.e., no trip signals) prior to entering MODE 2, and while in MODE 2 prior to startup of the first TDMFP. The TDMFPs exhaust their steam into the Main Condensers. Therefore if there is no vacuum in the Main Condensers, the TDMFP cannot be reset, or if while in MODE 2, condensor vacuum must be taken out, an Auxiliary Feedwaier Actuation will occur.

This proposed amendment allows this signal to remain blocked until a TDMFP is placed in service, and when shutting down to allow blocking the signal before securing the last TDMFP. This action is consistent with the following statements in th' NRC Safety Evaluation Report.- NUREG 0830, Section 7.3.2.7:

The signal which initiates auxiliary feedwater when the main feedwater pumps are tripped is manually blocked on normal shutdown of the main feedwater pumps. The design is such that the block is not l automatically removed when the plant is returned to an operating mode l

where auxiliary feedwater initiation on loss of main feedwater is

! needed. Even though the signal to initiate auxiliary feedwater when the main feedwater pumps are tripped is considered to be an l

' anticipatory signal,' for which no credit is taken in the analyses

! in SNUPPS FSAR Chapter 15, the staff position was that the design should include appropriste features to ensure that the block is removed when the plant is returned to an operating mode where auxiliary feedwater initiation on loss of main feedwater is needed.

The applicant has committed to provide automatic indication of the

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Attachment I to WM 88-0180 Page 2 of 3 July 6, 1988 block of the signals which initiate auxiliary feedwater on loss of both main feedwater pumps on the bypassed and inoperable status panel. Operating procedures will limit the operating modes during-which the block can be in effect. Blocking will be permitted just before shutdown of the last operating main feedwater pump and removed just after the first main feedwater pump is put into' service. .The staff concludes that the appifcant's design and operating procedures will provide adequate assurance that the auxiliary feedvater start signal on loss of both main feedwater pumps will not be blocked during operating modes when the diversity of this signal is desirable. The applicant'c design is, therefore, acceptable. The license will be conditioned to require the bypassed and inoperable status panel indication described above.

In accordance with the above, the blocking of the TDMFP and associated indication is described in USAR Section 7.3.6.1.1. There is no need for the Auxiliary Feedwater Actuation function below SI power, since there is sufficient time for operator actions to occur prior to steam generator levels decreasing to the low-low level reactor trip setpoint.

Should no operator actions occur, the reactor will trip and both motor driven auxiliary feedwater pumps will start when the first steam generator level drops to the low-low level setpoint. Should a second steam generator level reach its low-low level setpoint, the turbine driven auxiliary feedwater pump starts. With all 3 auxiliary feedwater pumps, the steam generator levcis are rapidly recovered. Procedurally, the signal will be unblocked just after the first TDMFP is placed in service during startups, and will be blocked just prior to securing the last TDMFP during shutdowns.

This proposed amendment revises Wolf Creek Generating Station (WCGS), Unit No.

1, Technical Specification Tables 3.3-3 and 4.3-2, which address the Engineered Safety Features Actuation System Instrumentation. This amendment request removes the MODE 2 applicability requirements from TABLE 3.3-3 Functional Unit 6.g and TABLE 4.3-2 Functional Unit 6.g. "Trip of All Main Feedwater Pumps - Start Motor Driven Pumps".

1) The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report has not increased. No credit was taken in the safety analysis for the auxiliary feedwater actuation signal as a result of the trip of all 7DMFPs in either MODE 1 or MODE 2. The proposed change does not effect the availability of any other protective features.

2) The possibility of an accident or nalfunction of a different type than any evaluated previously in the safety analysis report has not been created. This proposed amendment only effects an automatic start of the motor driven auxiliary feedwater pumps upon a trip signal from both TDMFPs while in MODE 2. This proposed amendment does not effect an auxiliary feedwater actuation on low-low steam generator level, which assures a heat sink for the reactor. This change does not involve any design changes to existing plant systems or the addition of any new equipment or systema.

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. At'tachment I'to WM-88-0180 .

, 'Page. 3'of.3 July' 6 ,- 1988 1

3) 'The margin of safety as. defined in the basis for any technical-

specification has not been reduc'ed.. This start signal was not taken credit- for in the safety.analysin. .This signal is' strictly an anticipatory function. ThereLis no shange to a margin of safety.

Based 'on the above discussions and the1 considerations presented.in Attachment-II .- ;the proposed revisions'to 'the WCGS Technical Specifications _ do not increase the probability of_occurrenceaor.- the consequences of an accident or

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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 reports or reduce the margin of, safety as defined in the basis for any technical specification. Therefore, the proposed revisions do not adversely affect or endanger the health or safety of the general public or involve a significant safety. hazard.'

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ATTACHMENT II ADDRESSING THE STANDARDS IN 10 CFR 50.92 I

Attachment.II to WM 88-0180 Page . 1 of 1 July 6 ',1988 i

ADDRESSING THE STANDARDS IN 10 CFR 50.92 This proposed amendment' revises Wolf Creek Generating' Station (WCGS)', Unit No.

1, Technical Specification Tables 3.3-3 and 4.3-2,. which address the Engineered Safety Features Actuation System Instrumentation. This amendment request removes the MODE 2 applicability requirements from TABLE 3.3-3 Functional Unit 6.g and TABLE 4.3-2 Functional Unit 6.g. "Trip of All Main

'Feedwater Pumps - Start Motor Driven Pumps".

1) The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated. .No credit was taken in the safety analysis for the auxiliary feedwater actuation signal as a result of the trip of all main feedwater pumps in either MODE 1 or MODE 2. The proposed change does not effect the availability of any other protective features.

2) The proposed amendment does not create the possibility .of a new or different kind of accident from any accident previously evaluated.

This proposed amendment does not effect an auxiliary feedwater actuation en low-low steam generator level, which assures a heat sink for the reactor. This change does not involve any design changes to existing plant systems or the addition of any- new equipment or systems.

3) The proposed amendment does not involve a significant reduction in a margin of safety. This signal is strictly an anticipatory function.

There is no change to a margin of safety.

Based on the above discussions and those presented in Attachment I, it han been determined tbat the requested Technical Specification revisions do 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 over previous evaluations; or involve a significant reduction in a margin of safety. Therefore, the requested license amendment does not involve a significant hazards consideration.

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