ML20154R793
| ML20154R793 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/27/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20154R796 | List: |
| References | |
| KMLNRC-86-054, KMLNRC-86-54, TAC-61085, NUDOCS 8603310192 | |
| Download: ML20154R793 (14) | |
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F KANSAS GAS AND ELECTRIC COMPANY THE ELECTAC COMPANY GLENN L KOESTER wrct petsetNT . nucogan March 27,1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Ccrmission Washington, D.C. 20555 KMIRRC 86-054 Re: Docket No. STN 50-482 Subj: Revision to Technical Specification 4.7.8
Dear Mr. Denton:
The purpose of this letter is to transmit three original and 4PI conformed copies of an application for Amendment to Facility Operating License No.
NPF-42 for Wolf Creek Generating Station, Unit No.1.
This application requests that the Wolf Creek Generating Station, (WCGS)
Unit No. 1 Technical Specifications, be revised to allow a deferment of the inservice visual inspection of safety related and special scope inaccessible snubbers. The determination of accessibility is based upon the existing radiation levels and the expected time to perform a visual inspection as well as other factors during plant operations (tenperature, atnosphere, location). In order to perform these inspections on inaccessible snubbers, the plant must be in at least Mode 2 (STARTUP) due to ALARA considerations.
'Ihe proposed change to the Technical Specifications is provided as Attachment III.
Section 4.7.8.b requires the first inservice visual inspection to be perforned after 4 nonths but within 10 nonths of POiER OPERATICN for both inaccessible and accessible snubbers. The first refueling outage (Refuel 1) is the next scheduled shutdown and is currently scheduled to begin in i October, 1986. In the event of any unanticipated delays in the refueling schedule a unit shutdcun to perform these inspections will be initiated by October 31, 1986. Therefore this request entails an approximate four nanth extension of the existing surveillance requirements. If an unscheduled shutdown of sufficient duration and resulting in appropriate plant conditions, as specified above, occurs prior to Refuel 1, Kansas Gas and Electric Cmpany (KG&E) will perform all inspections that can be cmpleted.
Without the requested revision Wolf Creek Generating Station wculd be forced into an outage for the sole purpose of inspecting inaccessibl snubbers.
8603310192 860327 PDR efje/Y f
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PDR ( p 201 N. Market - Wichita, Kansas - Mail Address: PO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 2616451 l
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Mr. H. R. Denton I<MIERC 86-054 Page 2 March 27, 1986 l
I l KG&E desires to kcap Wolf Creek Generating Station on line to support system i power needs until. Refuel 1. 'Ibiporary deferment of these tests will allow j KC&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 management. ,
'Ihe requested revision would rot have a significant inpact on safe i operations of the plant when ocmpared to the transient associated with a shutdown for the purpose of performing this surveillance. A ocuplete Safety Evaluation and Significant Hazards Consideration are provided as Attachment I and II respectively.
i 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. 2171) for the $150.00 application fee required by 10 CFR 170.21.
If you have any questions concerning this matter, please contact me or Mr.
O. L. Maynard of my staff.
Very truly yours, l u r ~.
l Glenn L. Koester
) Vice President - Nuclear )
GI,K:see I
e ablosure
' Attachments: I-Safety Evaluation j II-Significant Hazards Consideration III-Proposed Technical Specification Gange j
cc: PO'Connor (2), w/a JCtmtuns, w/a GAllen,w/a EJohnson,w/a 4
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i OATH OF AFFIRMATION STATE OF KANSAS )
) SS:
COUNTY OF SEDGWICK )
I, Kent R. Brown, of lawful age, being duly sworn upon oath, do depose,
, state and affirm that I am Group Vice President - Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the
] foregoing letter of transmittal for Glenn L. Koester, Vice President -
j Nuclear of Kansas Gas and Electric Company, know the contents thereof, l
4 and that all statements contained therein are true.
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3 KANSAS GAS AND ELECTRIC COMPANY ATTEST: ' '
By 4M, -
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- Kent R. Brown J
4 Group Vice President - Technical Servicer i
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j STATE OF KANSAS )
I
) SS:
COUNTY OF SEDGWICK )
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BE IT REMEMBERED, that on this 27th day of March , before me, Kent R. Brown , a Notary, personally appeared Kent R. Brown, Group Vice President - Technical Services of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known to me and who executed ,
! the foregoing instrument, and he duly acknowledged the execution of the 2
same for and on behalf of and as the act and deed of said Corporation.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal the date and year above written.
- p (' mAsa/
F~/' ~ f Notary i ! , .-
ij bepTiepty j.c. ,ny Commission expires August 15, 1989
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Mr. H. R. Nnton Attachnent I to KMINRC 86-054 Page 1 of 4 SAFETY EVALUATION This application requests a revision to the Wolf Creek Generating Station, Unit No.1, Technical Specifications Section 4.7.8.b to allow a deferment of the first inservice visual inspection of safety related inaccessible snubbers until the first refueling outage (Refuel 1). The determination of accessibility is based upon the existing radiation levels and the expected time to perform a visual inspection as well as other factors during plant operations (teTperature, attrosphere, location). Due to AIARA considerations, the inspection of inaccessible snubbers at POWER OPERATION is undesirable and not consistent with KG&E's AIARA program. We proposed change to the Technical Specifications is provided as Attachment III.
Section 4.7.8.b requires the first inservice visual inspection to be perfr_med after 4 rrenths but within 10 rrenths of PNER OPERATION for both inaccessible and accessible snubbers. Refuel 1 is the next scheduled shutdown and is currently scheduled to begin in October, 1986. In the event of any unanticipated delays in the refueling sdiedule a unit shutdown to perform these inspections will be initiated by October 31, 1986. %erefore this request entails an approximate four nonth extension of the existing surveillance requirenent. If an unscheduled shutdown of sufficient duration and resulting in appropriate plant conditions, as specified above, occurs prior to Refuel 1, Kansas Gas aryl Electric Ocupany (KG&E) will perform all inspections that can be otxnpleted. Without the requested revision hblf Creek Generating Station would be forced into an outage for the sole purpose of inspecting inaccessible snubbers.
There are approximately 1210 safety related and special scope snubbers installed at Wolf Creek Generating Station. Of these, approximately 780 are classified as accessible and approximately 430 are classified as inaccessible. Approximately 480 of the 780 accessible snubbers have been inspected and the remaining accessible snubbers will be inspected prior to the required due date associated with the surveillance. Of the 430 inaccessible snubbers, approximately 300 have been inspected within the inspection period leaving approximately 130 snubbers. This Technical Specification revision would defer the visual inspection of these 130 inaccessible snubbers which is 11 percent of the 1210 snubbers at Wolf Creek Generating Station. All snubbers inspected to date have been found to be OPERABLE with no evidence of any significant degradation.
Inaccessible Accessible All Snubbers Snubbers Snubbers Snubbers %at Have Been 300 480 780 Inspected And Found Acceptable 1
Snubbers That Have Not 130 300 430 Been Inspected Tbtal Number 430 780 1210 1 These snubbers will be inspected prior to the due date associated with surveillance.
i Mr. H. R. Denton Attachment I to IHINRC 86-054 Page 2 of 4 Within the four to ten tronth period of the snubber inspection period Wolf Creek Generating Station has operated in lede 1 (POWER OPERATION) for the whole period except for 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> early in the fourth month and for 57.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in February when the 300 inaccessible snubber assemblies were visually inspected. In early October, 1985, no snubbers were inspected during two outages totaling 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> because at that time Kansas Gas & Flectric believed there would be other outages with sufficient time to ccrnplete the I
snubber inspections. However, with the exertplary operating history of Wolf '
j' Creek Generating Station there has not been sufficient time at acceptable conditions to cmplete inspections of all inaccessible snubbers. Kansas Gas and Electric will take advantage of any unplanned reactor trips between now and the first refueling outage to accmplish as many inspections of inaccessible snubbers as possible.
Wolf Creek Generating Station utilizes only mechanical snubbers with the exception of 16 large bore hydraulic snubbers used in conjunction with its fmr steam generators. Mechanical snubbers are of the same type but vary in regard to size, environment, and loading. All mechanical snubbers at Wolf Creek Generating Station were manufactured by Pacific Scientific and the hydraulic snubbers were manufactured by Paul Munroe.
Prior to initial installation in the power block, each snubber was visually inspected and mechanically tested to ensure their operability prior to installation. %e mechanical portion of this test consisted in part of an acceleration test and a drag force test. Snubber assemblies were not actually installed in the power block until approximately one year prior to Ibt Functional Testing. %is served to preclude unnecessary exposure of the snubber assemblies to the construction environment present prior to this tirm. During installation snubber assaublies were verified to have the carrect pin-to-pin dimensions and appropriate swing clearance. A manual stroke test was also performed and verified.
j Subsequent to installation, systen walkdowns were performed by the
, constructor, KG&E, and the Architect / Engineer to verify correct installation and appropriate configuration. Additionally, approximately 40 percent of the snubber assemblies were inspected to fulfill preservice inspection program requirements. Inspections were also performed during Hot Ebnctional Testing ard unit startup to assure snubber operability was not adversely
, affected by normal thermal expansion. We aforerentioned cmprehensive preservice testing and inspection program ensured that the snubber assemblies at Wolf Creek Generating Station were fully operational prior to the beginning of Ominercial Operaticn.
In early September 1985, approximately three months after initial Power Operation at Wolf Creek Generating Station, 238 snubbers were inspected by KG&E personnel to determine if any snubber assenblies were damged during construction or unit startup. Although one snubber was found to be l q
inproperly oriented, no other anmolies were identified. We ancrrolous snubber was reoriented and all 238 snubber assenblies were determined to be fully operable.
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Mr. H. R. Denton Attachment I to IHIRRC 86-054 Page 3 of 4 Since initially entering bbde 3 (HOT STANDBY) on April 26, 1985, the Unit has not reentered Fbde 4 (iUP SHtfrDOWN). Wolf Creek Generating Station ccnmenced POWER OPERATION on June 6, 1985. Although Wolf Creek Generating Station has experienced four inadvertant safety injections since initially loading fuel, ite overall operating history has been exmplary for a first cycle unit, incitrling a continucus run of 134 days. We good perforrance of the unit has served to minimized the number of cyclical loadings experienced by the snubber ass mblies.
After a Unit trip on February 22, 1986, approximately 320 snubber assemt> lies inside contairumnt were inspected. We majority of these had been categorized as inaccessible during POWER OPERATION. All inspected snubber assemblies were c'etermined to be operable. One of the steam generator hydraulic snubbers was observed to be leaking scme fluid, however, this did not impair its operability. he fluid reservoir level for this snubber is being monitored to assure its continued operability.
Since inspections of 64 percent of all safety related and special scope snubber assemblies and 70 percent of all inaccessible snubber ass mblies confinmd that all inspected snubbers were visually acceptable and considered operable, it is probable that no inoperable snubbers will be identified during inspections of the remining inaccessible snubbers. In addition, a four month extension of the existing surveillance requirement, during a period of continuous POWER OPERATION, is unlikely to have any effect on snubber assably operability.
Technical Specifications require a visual inspection of all snubbers betwen four and ten nonths after initial POWER OPERATION. %is requirement ensures that installed snubbers remain undamaged and in the appropriate configuration after plant thermal cycles, normally present during the early phases of Cycle 1 operation, have occurred. It further serves to provide baseline information upon which future visual snubber ass ably testing intervals can be established as provided in Technical Specifications. Since 70 percent of all inaccessable snubber assemblies have successfully passed an initial visual inspection, it is expected that any inaccessable snubber assemblies not yet inspected are fully capable of performing their design function as assumed in the FSAR accident analyses. %erefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident over previous evaluations.
%e proposed a:mndrmnt does not involve hardware tradifications, introduces no new systes, modes of operation, failute nodes or other plant perturbaticns . here is a high level of assurance of snubber assembly operability, since during inspections of 64 percent of all installed safety related and special scope snu1ber assemblies all snubber assmblies passed the surveillance and were determined to be operable. Werefore, the j proposed amendment does not create the possibility of a new or different l kind of accident over previous evaluations. l 1
Mr. H. R. Denton Attachment I to KMLNRC 86-054 Page 4 of 4 The requested amendment merely extends an existing surveillance interval to allos concinued POWER OPERATION until Refuel 1. During periods of continuous operation at poaer, minirni cyclical wear of snubber assenblies occurs. The inspections performed to date indicate that the installed snubber assenblies have performed in a wholly satisfactory manner and can be expected to maintain that level of performance. Thus the proposed amendment does not involve a significant reduction in a margin of safety.
Based on the above analysis, the proposed revision to the Wolf Creek Generating Station, Unit No. 1, Technical Specifications does not adversely affect or endanger the health or safety of the general public or involve an unreviewed safety question.
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J Mr. H. R. Denton
! Attachment II to KMENRC 86-054 Page 1 of 4 SIGNIFICANT HAZARDS CONSIDERATION 4
his application requests a revision to the Wolf Creek Generating Station, l Unit No.1, 'Ithcal Specifications Section 4.7.8.b to allow a deferment of j the first inservice visual inspection of safety related inaccessible
- snubbers until the first iefueling outage (Refuel 1). We determination of j accessibility is based upon the existing radiation levels and the expected time to perform a visual inspeciton as well as other factors during plant operations (tmperature, atnesphere, location). Due to ALARA considerations, the inspection of inaccessible snubbers at POWER OPERATION is undesirable and not consistent with KG&E's ALARA program. %e proposed change to the Technical Specifications is provided as Attachment III.
- Section 4.7.8.b requires the first inservice visual inspection to be l
perfonned after 4 nonths but within 10 nonths of POWER OPERATION for both inaccessible and accessible snubbers. Refuel 1 is the next scheduled shutdown and is currently scheduled to begin in October,1986. In the ever.t of any unanticipated delays in the refueling schedule a unit shutdoan to perform these inspections will be initiated by October 31, 1986. Werefore this request entails an approximate four month extension of the existing surveillance requirement. If an unscheduled shutdown of sufficient duration and resulting in appropriate plant conditions, as specified above, occurs prior to Refuel 1, Kansas Gas and Electric Ccapany (KG&E) will perform all
- inspections that can be ampleted. Without the requested revision Wolf l Creek Generating Station would be forced into an outage for the sole purpose 4
of inspecting inaccessible snubbers.
%ere are approximately 1210 safety related and special scope snubbers j installed at Wolf Creek Generating Station. Of these, approximately 780 are classified as accessible and approximately 430 are classified as inaccessible. Approximately 480 of the 780 accessible snubbers have been 1 inspected and the remaining accessible snubbers will be inspected prior to the required due date associated with the surveillance. Of the 430 inaccessible snubbers, approximately 300 have been inspected within the inspection period leaving approximately 130 snubbers. Bis Technical Specification revision would defer the visual inspection of these 130 inaccessible snubbers which is 11 percent of the 1210 snubbers at Wolf Creek Generating Station. All snubbers inspected to date have been found to be OPERABLE with no evidence of any significant degradation.
Inaccessible Arvwmible All andbers th 4bers Snnhbrs i Snubbers hat Have Been 300 480 780 Inspected And Found 4 Acceptable 1
Snubbers %at Have Not 130 300 430 Been Inspected 4 'Ibtal Ntriber 430 780 1210 1 %ese snubbers will be inspected prior to the due date associated with surveillance.
l Mr. H. R. Denton Attachment II to KMWRC 86-054 Page 2 of 4 Within the four to ten month period of the snubber inspection period Wolf Creek Generating Station has operated in m de 1 (POWER OPERATION) for the whole period except for 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> early in the fourth roonth and for 57.3 l hours in February when the 300 inaccessible snubber assertblies were visually
! inspected. In early October, 1985, no snubbers were inspected during two l outages totaling 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> because at that time Kansas Gas & Electric believed there would be other outages with sufficient time to cmplete the snubber inspections. Hcwever, with the exenplary operating history of Wolf l
Creek Generating Station there has not been sufficient time at acceptable
- ccnditions to cmplete inspecitons of all inaccessible snubbers. Kansas Gas and Electric will take advantage of any unplanned reactor trips between now and the first refueling outage to acconplish as many inspections of j inaccessible snubbers as possible.
Wolf Creek Generating Station utilizes only mechanical snubbers with the exception of 16 large bore hydraulic snubbers used in conjunction with its four steam generators. Mechanical snubbers are of the same type but vary in regard to size, environment, and loading. All mechanical snubbers at Wolf Creek Generating Station were manufactured by Pacific Scientific and the hydraulic snubbers were manufactured by Paul Munroe.
Prior to initial installation in the power block, each snubber was visually inspected and mechanically tested to ensure their operability prior to installation. %e mtrhanical portion of this test consisted in part of an acceleration test and a drag force test. Snubber assemblies were not actually installed in the power block until approximately one year prior to Hot Functional Testing. his served to preclude unnecessary exposure of the snubber ass mblics to the construction environment present prior to this tine. During installation snubber assmblies were verified to have the correct pin-to-pin dimensions and appropriate swing clearance. A manual stroke test was also performed and verified.
- Subsequent to installation, system walkdowns were performed by the constructor, KG&E, and the Architect / Engineer to verify correct installation i and appropriate configuration. Additionally, approximately 40 percent of the snubber assablies were inspected to fulfill preservice inspection program requirements. Inspections were also performed during Hot Functional Testing and unit startup to ass 0re snubber operability was not adversely
, affected by normal thermal expansion. he aforementioned conprehensive ,
! preservice testing and inspection program ensured that the snubber I assemblies at Wolf Creek Generating Station were fully operational prior to I the beginning of Omnercial Operation. ;
In early September 1985, approximately three nr;nths after initial Ibwer
- Operation at Wolf Creek Generating Station, 238 snubbers were inspected by I
KG&E personnel to determine if any snubber ass ablies were damaged during I construction or unit startup. Although one snubber was found to be improperly oriented, no other anemolies were identified. he anmolous snubber was reoriented and all 238 snubber assemblies were determined to be fully operable.
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Mr. H. R. Denton Attachment II to IHIRRC 86-054 Page 3 of 4 Since initially entering obde 3 (HOT STANDBY) on April 26, 1985, the Unit has not reentered bbde 4 (IOT SHU'ITXMN) . Wolf Creek Generating Station ccumenced POWER OPEPATION on June 6, 1985. Although Wolf Creek Generating Station has experienced four inadvertant safety injections since initially loading fuel, its overall operating history has been exemplary for a first cycle unit, including a continuous run of 134 days. We good performance of the writ has served to minimized the nunber of cyclical loadings experienced by the snubber assemblies.
After a Unit trip on February 22, 1986, approxinately 320 snubber assemblies inside containment were inspected. We majority of these had been categorized as inaccessible during POWER OPERATION. All inspected snubber assemblies were determined to be operable. One of the steam generator hydraulic snubbers was observed to be leaking scme fluid, however, this did not impair its operability. %e fluid reservoir level for this snubber is being nonitored to assure its continued operability.
Since inspections of 64 percent of all safety related and special scope snubber assemblies and 70 percent of all inaccessible snubber assemblies confirmed that all inspected snubbers were visually acceptable and considered operable, it is probable that no inoperable snubbers will be identified during inspections of the remaining of inaccessible snubbers. In addition, a four nonth extension of the existing surveillance requirement, during a period of continuous POWER OPERATION, is unlikely to have any effect on snubber assenbly operability.
Technical Specifications require a visual inspection of all snubbers between four and ten nonths after initial POWER OPERATION. his requiramnt ensures that installed snubbers remain undamaged and in the appropriate configuration after plant thennal cycles, normally present during the early phases of Cycle 1 operation, have occurred. It further serves to provide baseline information upcn which future visual snubber assenbly testing intervals can be established as provided in Technical Specifications. Since 70 percent of all inaccessable snubber assemblies have successfully passed an initial visual inspection, it is expected that any inaccessable snubber assenblies not yet inspected are fully capable of performing their design function as assumed in the FSAR accident analyses. Werefore, the proposed anendment does not involve a significant increase in the probability or consequences of an accident over previous evaluations.
We proposed amendment does not involve hardsare nodifications, introduces no new systems, nodes of operation, failure modes or other plant , i perturbations. W ere is a high level of assurance of snubber assembly operability, since during inspections of 64 percent of all installed safety related and special scope snubber assanblies all snubber assanblies passed the surveillance and were determined to be operable. Werefore, the j proposed amerdment does not create the possibility of a new or different l kind of accident over previous evaluations. '
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Mr. H. R. Denton Attachment II to KMINRC 86-054 Page 4 of 4 h e reque3ted amendment merely extends an existing surveillance interval to allow continued POWER OPERATION until Refuel 1. During periods of continuous operation at power, minimal cyclical wear of snubber asseTblies occurs. %e inspecticns performed to date indicate that the installed snubber assenblies have performed in a wholly satisfactory manner and can be expected to maintain that level of performance. Bus the proposed amendment does not involve a significant reduction in a margin of safety.
We Ommission has provided guidance concerning the application of the standards in 10 CFR 50.92 by providing examples of amendments that are not likely to involve Significant Hazards Considerations (48 FR 14870). Among these examples is, "A change which either may result in scme increase to the probability or consequences of a previously analyzed accident or may reduce in scme way a safety margin, but where the results of the change are clearly within all acceptable criteria with respect to the systen or conponent specified in the Standard Review Plan:" h e proposed license amendment fits this exanple in that it reflects a four nonth extension of a visual surveillance requirenent used to gather and establish baseline information cn snubber assembly performance.
Based on the above analysis and the guidance provided by the Omnission, 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 possiblity of a new or different kind of accident or condition over previous evaluation; or involve a significant reduction in a margin of safety.
%erefore the requested license amendment does not present a significant hazard.
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