ML20154S584
| ML20154S584 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/23/1998 |
| From: | Muench R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20154S589 | List: |
| References | |
| ET-98-0087, ET-98-87, NUDOCS 9810280027 | |
| Download: ML20154S584 (5) | |
Text
-
f i
W$LF CREEK
_k President Engineering NUCLEAR OPERATING 3 g
%4 Vk ET 98-0087 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Statjon pl-137 Washington, D.-C.
20555
Reference:
- 1) Letter WO 98-0078 dated August 5,
1998, from C.
C.
Warren, to USNRC
- 2) Letter ET 98-0078 dated September 24, 1998, from R.
A.
Muench, to USNRC
- 3) Letter ET 97-0050, dated May 15,
- 1997, frem R. A. Muench to USNRC i
Subject:
Docket No. 50-482: Follow-up Items Related to the Proposed Conversion to the Improved Technical Specifications Section 3.1, 3.2, 3.4, 3.5, and 5.0 Gentlemen:
l Wolf Creek Nuclear Operating Corporation (WCNOC) requested an amendment to the Wolf Creek Generating Station (WCGS) Unit 1 facility operating license (NPF-
- 42) by incorporating changes to the WCGS Technical Specifications (TS) as provided in Reference 3.
The NRC staff requested additional information l
regarding Section 3.1,
" Reactivity Control Systems," Section 3.2,
" Power l
Distribution Systems," Section 3.5,
" Emergency Core Cooling Systems," Section l
- 3. 9,
" Refueling Operations," and 4.0,
" Design Features," which was provided in Reference 1.
In addition, the PRC staff requested additional information regarding Section 3.4,
and Section 5.0, L
- " Administrative Controls," which was provided in Reference 2.
The Attachments to this letter provide (1) additional information or supporting documentation not provided in the original Request for Addition Information response, (2) answers tu follow-up questions, or (3) additional changes identified by the licensee.
This letter and Enclosure are not a supplement to Reference 3 and have not been _ reviewed by the Plant Safety Review Committee or Nuclear Safety Review
. Committee. A supplement to Reference 3 will be provided at a later date.
If you have any questions concerning this response, please contact me at (316) 364-4034, or Mr. Michael J. Angus, 316-354-4077.
Very trul yours, 9810280027 981023 PDR ADOCK 0500 2
Richa d A. Muench Attachments
...y Enclosure
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D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a B. A. Smalldridge (NRC), w/a K. M. Thomas (NRC), w/a PO. Box 411/ Burlington, KS 66839 / Phone: (316) 064 8831 An Equal Opportunity Empbyer M/F/HCNET
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l Richard A. Muench, of lawful age, being first duly sworn upon oath says that i
he 'is Vice President Engineering of Wol f Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the content thereof; that i
l he has executed that same for and on behalf of said Corporation with full l
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, l
By Richard. Muench Vice Pr sident Engine ing DUBSCRIBED and sworn to before me this b dayofbckokf",
1998.
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OdAollA Iggg Notary Public 9
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Att: chm:nt 1 to ET 98-0087 Pcgn 1 of 1 Th,e item numbers are formatted as follows: [ Source] [lTS Section)-[nnn)
Source =
Q - NRC Question NR - NRC Follow-up Question CA - AmerenUE DC-PG&E WC - WCNOC CP - TU Electric TR - Traveler ITS Item Number Applicability Enclosed 3.1 Q 3.1-19 CA, WC YES 3.1 Q 3.1-20 CP,DC NA 3.1 CA 3.1-005 (new)
CA NA 3.2 Q 3.2-3 CA, CP, DC, WC,
YES 3.4 Q 3.4.13-5 DC NA 3.4 Q 3.4.13 CA NA 3.5 Q 3.5.5-1 CP,DC NA 3.5 CA-3.5-001 CP (new)
NA 3.5 CA-3.5-002 CA, CP, DC, WC YES 3.5 CA-3.5-004 (new)
CA NA 3.5 CP 3.5-003 (new)
CP NA 3.5 DC-3.5-002 DC NA 3.5 DC 3.5-006 DC NA 5.0 NR-5.0-001 (new)
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.1-19 APPLICABILIT9 CA, WC REQUEST:
ITS 3.1.7 Rod Position Indication CTS 3.1.3.2 Position Indication Systems - Operating (Wolf Creek & Callaway)
DOC 13-05-A & 13-09-LS-23 & 13-06-A JFD 3.1-7 & 3.1-12 Comment: The ITS retains Conditions and associated Required Actlcas from the CTS addressing more than one inoperable digital rod position indicator (DRPI) per group, which is not addressed in the STS. However, not all associated CTS Required Actions have been retained in the ITS; the Required Actions to take manual control of the rods and to record reactor coolant temperature every hour have not been retained. These actions, in one case affect rod movement and in the other case provide an indication that the rod (s) position may have changed, and therefore have a bearing on SDM and therefore should not be deleted if the overall condition of more than DRPl per group is iroperable is retained. Either retain the CTS requirements completely, adopt the STS re quirements, or provide a better justification for the ITS proposals. The STS wording of the note permitting separate condition entry should be retained with the STS Conditions and Required Actions.
FLOG RESPONSE: (original) The wording of ITS Condition B, with its Required Actions B.1 and B.2, and the change to the Actions Note on separate Condition entry were made pursuant to traveler TSTF-234. TSTF-234 was createa based on the Callaway and Wolf Creek CTS; however, Westinghouse and the Westinghouse Owne,rs Group felt that Action Statements b.1.b) and b.1.c) were unnecessary compensatory actions. The justifications for deleting CTS 3.1.3.2 Action Statements b.1.b) and b.1.c) are discussed in under LS-23. In order to capture tho* ijustifications under A, DOC 13-09-LS-23 is revised to add the following:
"The proposed change wwid delete the Actions to place control rods in manual and record RCS T hourly if multiple DRPIs per group are y
inoperable. Multiple inoperable DRPIs, of themselves, have no impact on SDM in MODES 1 and 2 if the control rod positions are verified by alternate means (e.g., movable incore detectors). The requirement to place control rods in manual may not be appropriate in all situations and may be detrimental for load rejection transients unless operator action is assumed to simulate the rod control system in automatic. Accidents analyzed using the (Revised Thermal Design Procedure (RTDP)] assume that the control rods are in (their most limiting mode). Automatic rod movement can accommodate a 10% load rejection. Placing rods in manual may impact the load rejection capability assumed when the P-9 setpoint was established at 50% RTP. The steam dump system can accommodate a 40% RTP load rejection and with the rod control system in automatic, a 50% RTP load rejection can be accommodated without a reactor trip. While manual operator action can be just as timely as automatic rod control, there is no need to have this limitation in the Techtucel Specifications. Corrective actions for enssive rod motion are covered under ITS 3.1.7 Condition C. The requirement to monitor and
1
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record T,y hourly is unnte:ssary given tha availabla indicators and alarms, e.g., T,y - T,, deviation alarm, to alert operators to changing moderator conditions."
l FLOG RESPONSE (revised): This is a modified response, which replaces the original l
response provided in Reference 2 of the cover letter, in order to respond i
to NRC reviewer comments.
l The wording of ITS Condition B, with its Required Actions B.1 and B.2, and the change to the Actions Note on separate Condition entry were l
made pursuant to traveler TSTF-234. TSTF-234 was created based on I
the Ca'laway and Wolf Creek CTS; however, Westinghouse and the l
Westingrause Owners Group felt that Action Statements b.1.b) and b.1.c) were unnecessary compensatory actions. The justifications for deleting CTS 3.1.3.2 Action Statements b.1.b) and b.1.c) were discussed in under LS-23. However, based on NRC staff review, ITS 3.1.7 Condition B will be revised to include Required Actions to place the control rods in manual and to monitor and record RCS T,y hourly, as required by the current TS. The separate condition entry note does not need to include "per group" or "per bank" since the wording of the respective Conditions already provides those restrictions and including that wording in the note is redundant and potentially misleading to the operator. This is an editorial change.
ATTACHED PAGES:, CTS 3/4.1 -ITS 3.1 Encl. 2 1-11 Encl.3A 13 Encl. 3B 8
Encl. 4 1,53,54 Encl. 5A Traveler Status page, 3.1-17,3.1-18 Encl. SB B 3.1-48 Encl. 6A 2
Encl. 6B 2
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