ML20196J399

Application for Amend to License NPF-42,revising Wording of Action Statement 5a to TS Table 3.3-1, Reactor Trip Sys Instrumentation

ML20196J399
Person / Time
Site:	Wolf Creek
Issue date:	07/29/1997
From:	Muench R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20196J405	List: ML20196J399 ML20196J407
References
ET-97-0071, ET-97-71, NUDOCS 9708040189
Download: ML20196J399 (12)

Text

4 Wf LF CREEK NUCLEAR OPERATING CORPORATION Richard A. Muench Vice President Engineering July 29, 1997 ET 97-0071 U.

S. Nuclear Regulatory Commissicn ATTN:

Document Control Desk Mail Station Pl-137 Washington, D. C.

20555

Reference:

1)

WCNOC Letter ET 95-0106, dated November 22, 1995, from R. A. Muench, WCNOC, to the NRC 2)

NRC Letter dated March 1,

1996, J.

C. Stone, NRC, to N. S. Carns, WCNOC 3)

WCNOC Letter ET 97-0050, dated May 15, 1997, from R. A.

Muench, WCNOC, to the NRC

Subject:

Docket No. 50-482:

License Amendment Request for Technical Specification 3/4.3.1, Table 3.3-1 Gentlemen:

This letter transmits an application for amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS).

This license amendment request revises the wording of Action Statement Sa to Technical Specification Table 3. 3 - 1,-

" Reactor Trip System Instrumentation."

This action statement prescribes a cet of actions to be accomplished when a source range neutron detector is inoperable with the plant shutdown.

The proposed wording change will clarify the times and order in which these actions are to be performed.

This proposed license amendment request is a corrective action for NRC Notice of Violation EA 96-470, Violation I.C, issued April 3, 1997.

It is requested that this proposed revision be approved and issued prior to September 15, 1997, for implementation prior to the ninth refueling outage.

Reference 3 provided an application for conversion of the current technical specifications to the improved standard technical specifications.

The attached proposed changes requested by this transmittal were incorporated into Reference 3 and, therefore, no markups are provided to identify the changes to the improved standard tecnnical specifications.

Reference 3 requested additional changes associated with source range neutron flux monitoring, but these changes are not being requested as part of this change to the current technical specification for WCGS.

This amendment request is intended to address only the ambiguities ' created with the implementation of Amendment No.

96 to the WCGS Technical Specifications, as discucsed in Attachment I.

A Safety Evaluation of the prcposed change is provided in Attachment I,

and Attachment II provides a No Significant Hazards Ct.nsideration Determination.

Attachment III is the Environmental Impact Determination for the proposed change, and the marked-up technical specification page for this request is provided in Attachment IV.

M O/

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9708040189 970729 PDR ADOCK 05000482 P

PDR l

P.O. Box 411 i Burhngton, KS 66839 / Phone: (316) 364 8831 i i *

• An Equal Opportunity Employer M f'HC/ VET

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'ET.97'0071 Page 2 of 2 l-In accordance with 10 CFR 50.91, a copy of this revision to our original l

application, with attachments, is being provided to the designated Kansas State Official.

I If you have any questions concerning this matter, please contact me at (316)'364-8831, extension 4034, or Mr. Richard D. Flannigan, at extension 4500.

Very truly yours, ldSN

{

Richard A. Muench RAM /jad Attachments I

- Safety Evaluation II - No Significant Hazards Consideration Determination III - Environmental Impact Determination IV - Proposed Technical Specification Change cc:

V.

L. Cooper (KDHE), w/a j

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D. Johnson (NRC), w/a i

E. W. Merschoff (NRC), w/a J.

F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a 1

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j STATE OF KANSAS

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SS COUNTY OF COFFEY

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I Richard A. Muenchi of lawful age, being first duly sworn upon oatih says ' that' he is Vice President. Engineering of Wolf Creek Nuclear Operating Corporation; that-i' he has read the. foregoing document and ~ knows the content thereof; that he has executed that same for and on behalf of said Corporation with full power and authority. to do so; and that.the facts therein stated are true and correct to

'l the'best of his knowledge, information and belief.

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BY Richard A'. Muench Vice President Engineering

.j SUBSCRIBED and sworn to before me'this day of' LJ 1997.

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Attachment I to ET 97-0071 Page 1 of 3 ATTACHMENT I l

SAFETY EVALUATION 1

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Attachment I to ET 97-0071 l

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Page 2 of 3 Safety Evaluation Proposed Change This license amendment request proposes to revise the Wolf Creek Generating Station (WCGS) Technical Specifications to revise the wording of Action Statement Sa to Technical Specification Table 3.3-1,

" Reactor Trip System Instrumentation."

This action statement prescribes a set of actions to be accomplished when a source range neutron detector (Functional Unit 6.b on Table 3.3-1) is inoperable with the plant shutdown.

The proposed wording change will clarify the times and order in which these actions are to be performed.

This proposed license amendment request is a corrective action for l

NRC Notice of Violation EA 96-470, Violation I.C, issued April 3, 1997 It is requested that this proposed revision be approved and issued prior to September 15, 1997, for implementation prior to the ninth refueling outage.

Technical Specification Table 3.3-1, Action Statement 5a currently states:

"With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the Reactor Trip Breakers, and suspend all operations involving positive reactivity changes within the next hour."

The proposed change would revise the action to state:

"With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

If the inoperable channel is not restored to OPERABLE within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />,

then, within the 49"'

hour, open the Reactor Trip Breakers and suspend all operations involving positive reactivity changes.

In addition, a typographical error is corrected in Action Statement 7.

The last word of that action statement, " operable," should be in all caps (i.e.,

" OPERABLE").

Background

On March 1,

1996, the NRC issued Amendment No.

96 to the WCGS Technical Specifications.

This amendment replaced the technical specification requirements associated with the boron dilution mitigation system with alarms, indicators, procedures and controls to allow proper resolution of potential boron dilution events.

As part of that amendment, Action Statement 5a to Technical Specification Table 3.3-1 was revised to delete the requirement to verify the closure of the two boron dilution valves.

Prior to the issuance of Amendnent No. 96, Action Statement 5a stated:

"With the number of OPERABLE channels one less than the minimum channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the Reactor Trip Breakers, suspend all operations involving positive reactivity changes and verify valves BG-V178 and BG-V601 are closed and secured in position within the next hour."

Amendment No. 96 reworded the action to state:

"With the number of OPERABLE channels one less than the Minimum Channels CPERABLE requirement, restore the inoperable channel to OPERABLE status I

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Attachment I to ET 97-0071 l.

Page 3 of 3 within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the Reactor Trip Breakers, and suspend all operations involving positive reactivity changes within the next hour."

l Evaluation In the action statement, as worded prior to Amendment No.

96, the clause requiring suspension of operations involving positive reactivity changes was one of three actions to be taken within one hour if the inoperable channel l

could not be restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

In other words, these three actions l

had to be completed within one hour following the 48-hour period.

The Westinghouse Standard Technical Specifications (NUREG 1431, Revision 1,

Section 3.3) supports this position.

Condition K,

associated with Table 3.3.1-1 Function 5, applies to one inoperable source range channel in Modes 3, 4,

or 5 with the reactor trip breakers (RTBs) closed and Control Rod Drive (CRD) System capable of rod withdrawals.

This action requires the licensee to l

restore the channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the RTB within 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br />.

The Bases explains that, "One additional hour is allowed to open the RTBs.

Once the RTBs are open, the core is in a more stable condition and the unit enters Condition L."

Condition L applies when the required number of operable source range neutron flux channels is not met in Modes 3,

4, or 5 with the RTBs open, and indicates the required number of operable source range neutron flux channels for these conditions is one.

Condition L requires the licensee to immediately suspend operations involving positive reactivity additions, close unborated source isolation valves within one hour, and begin j

performing certain surveillances within one hour.

Thus, according to NUREG-1431, Revision 1,

the requirement to suspend operations involving positive l

l reactivity is meant to apply only when the RTBs are opened and no source range l

neutron flux channels are operable.

When drafting the change to the action statement that was approved in l

Amendment No. 96, the "and" that had been between the words " changes" and

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" verify" had to be moved forward and commas relocated, for grammatical l

l reasons.

However, this did not change the relationship between the remaining

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phrases or the intended meaning of the remaining actions, or the time frame in which they are to be performed.

The intent of the change was only to delete the action involving the boron dilution valves.

The time frame for performing the actions of opening the reactor trip breakers and suspending l

operations involving positive reactivity changes were intended to remain as within one hour following the 48-hour period.

Unfortunately, editing the l

action statement to delete the one action created an ambiguity in the wording of the remaining actions, such that the relationship of the remaining actions l

to the 48-hour period was not clear.

i Changing the action statement to the proposed rewording will eliminate the ambiguity created by the implementation of Amendment No. 96 and clarify the j

proper time frames in which the required actions are to be performed, as explained in the Bases for Section 3.3 of NUREG-1431, Revision 1.

The proposed wording is consistent with the action as stated in NUREG-1431, Revision 1.

I Based on the above discussions and the No Significant Hazards Consideration Determination presented in Attachment II, the proposed change does not increase the probability of occurrence or the consequences of an accident or 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 report; er reduce the margin of safety as defined in the basis for any technical specification.

Therefore, the proposed change does not adversely j

affect or endanger the health or safety of the general public or involve a significant sr.fety hazard.

Attachment II to ET 97-0071 Page 1 of 3 ATTACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION l

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Attachment II to ET 97-0071 l

Page 2 of 3 No Significant Hazards Consideration Determination This license amendment request proposes to revise the Wolf Creek Generating Station (WCGS) Technical Specifications to revise the wording of Action Statement 5a to Technical Specification Table 3.3-1,

" Reactor Trip System j

Instrumentation."

This action statement prescribes a set of actions to be accomplished when a source range neutron detector (Functional Unit 6.b on Table 3.3-1) is inoperable with the plant shutdown.

The proposed wording change will clarify the times and order in which these actions are to be i

performed.

Technical Specification Table 3.3-1, Action Statement 5a currently states:

l "With the number of OPERABLE channels one less than the Minimum Channels l

OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or open the Reactor Trip Breakers, and suspend all operations involving positive reactivity changes within the next hour."

l The proposed change would revise the action to state:

l "With the number of OPERABLE channels ene less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

If the inoperable channel is not restored to OPERABLE th within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, then, within the 49 W

m de Rema TQ Breakers and suspend all operations involving positive reactivity changes.

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Standard I - Involve a

Significant Increase in the Probability or Consequences of an Accident Previously Evaluated In MODE 3, 4,

or 5 with the rod control system capable of rod withdrawal or rods not fully inserted, the source range neutron detectors provide a reactor trip signal on high neutron flux to provide core protection against an uncontrolled rod cluster control assembly bank withdrawal from a subcritical or low power startup condition.

This trip function is actuated when either of l

two independent source range channels indicates a neutron flux level above a j

preselected manually adjustable setpoint.

If the rod control system is not capable of rod withdrawal with rods fully inserted, the source range detectors are not required to trip the reactor.

NUREG-1431, Revision 1,

" Standard Technical Specifications Westinghouse Plants," allows one source range neutron detector to be out of service for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

One additional hour is allowed to open the reactor trip breakers and suspend operations involving the addition of positive reactivity.

This was the same action sequence prescribed for the source range neutron detectors prior to the implementation of Amend.nent No. 96 to the Wolf Creek Technical Specifications, which inadvertently resulted in an ambiguous rewording of the action.

The proposed rewording of the action statement clarifies the proper i

timing of the required actions, and is consistent with NUREG-1431, Revision 1.

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The proposed change does not introduce any new potential accident initiating conditions and does not alter any plant operating procedures or method of operation of any plant ccmponents or systems.

Allowing positive reactivity changes during the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period in which one source range neutron detector is inoperable is acceptable since the remaining detector will still provide the reactor trip function and control room indication when the reactor trip breakers are closed, and control room indication when the reactor trip breakers are open.

This is consistent with the provisions in NUREG-1431, Revision 1.

Thus, the proposed change does not affect any system's ability to

Attachment II to ET 97-0071 Page 3 of 3 1

mitigate the consequences of an accident and will not increase the probability of occurrence of any previously evaluated accident.

l Standard II - Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed change does not affect the method of operation of any plant component or system, and does not create any new, or alter any existing, accident initiators.

The proposed change clarifies that positive reactivity changes may be allowed during the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period in which a source range l

neutron detector is inoperable, as provided for in NUREG-1431, Revision 1.

l This action does not affect the capability of the remaining source range neutron detector to provide a reactor trip signal on high neutron flux during l

this period when the reactor trip breakers are closed, nor does it affect the l

ability of the remaining detector of providing control room indication.

This l

function of the source range neutron detectors is discussed in Chapter 15 of the Wolf Creek Updated Safety Analysis Report.

This proposed change does not I

modify any existing plant equipment, add any new plant equipment, or alter any component or system operating parameters or procedures.

Therefore, this proposed change will not create the possibility of a new or different kind of l

accident from any previously evaluated.

I Standard III - Involve a Significant Reduction in the Margin of Safety l

The source range neutron detectors provide a reactor trip function during shutdown conditions when the reactor trip breakers are closed.

When the reactor trip breakers are open they provide control room alarm / indication, l

only.

The proposed change clarifies that positive reactivity changes may be allowed during the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period in which a source range neutron detector is inoperable.

This is consistent with the provisions in NUREG-1431, Revision 1 and with Wolf Creek Technical Specification Table 3.3-1, Action 5.a, prior to l

the implementation of Amendment No. 96.

In Amendment No. 96 the wording of this action was changed such that this allowance was no longer clear.

With one source range neutron detector inoperable with the reactor trip breakers closed, the reactor trip on high neutron flux function is still provided by the remaining source range neutron detector.

With one source range neutron detector inop.erable with the reactor trip breakers open, control room indication of high neutron flux is still provided.

As stated above, this is consistent with NUREG-1431, Revision 1,

as well as with the action requirements prior to the implementation of Amendment No. 96.

This proposed change, then, does not affect the margin of safety provided by the source range neutron detectors.

i Based on the above discussions, 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

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previous evaluations; or create the rossibility of a new or different kind of l

accident or condition over previous evaluations; or involve a significant reduction in a margin of safety.

The requested license amendment does not involve a significant hazards consideration.

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Attachment III to ET 97-0071 l,

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ATTACHMENT III i

1 ENVIRONMENTAL IMPACT DETERMINATION i

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i Attachment III to ET 97-0071 Page 2 of 2 Environmental Impact Determination 10 CFR 51.22(b) specifies the criteria for categorical exclusions from the requirement for a specific environmental assessment per 10 CFR 51.21.

This amendment request meets the criteria specified in 10 CFR 51. 22 (c) ( 9) as specified below:

(i) the amendment involves no significant hazards consideration i

As demonstrated in - Attachment II, the proposed change does not involve any significant hazards consideration.

l (ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite The proposed change does not involve a change to the facility or operating procedures that would cause an increase in the amounts of effluents or create new types of effluents.

f (iii) there is no significant increase in individual or cumulative occupational radiation exposure The proposed change does not create additional exposure to personnel nor I

affect levels of radiation present. Also, the proposed change does not result in any increase in individual or cumulative occupational radiation exposure.

Based on the above it is concluded that there will be no impact on the environment resulting from this change and the change meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of f

10 CFR 51.21 relative to requiring a specific environmental assessment by the i

Commission.

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Attachment IV to ET 97-0071 Page 1 of 2 i.

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ATTACHMENT IV 4

PROPOSED TECHNICAL SPECIFICATION CHANGES I

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