ML20202C450
| ML20202C450 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/04/1998 |
| From: | Muench R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20202C454 | List: |
| References | |
| ET-98-0002, ET-98-2, NUDOCS 9802120249 | |
| Download: ML20202C450 (14) | |
Text
4 6
WedLF CREEK NUCLEAR OPERATING CORPORATION Rchard A. Muench Vme Peteident Engtreoring February 4, 1998 FT 90-0002 U. S. Nuclear Regulatory Commission ATTN Document Control Desk Mail Station Pl-137 Washington, D. C. 20555 References Letter ET 97-0050, dated May'15, 1997, f rom R. A. Muer ch, WCNOC to NRC Subject Docket No. 50-402: Proposed Revision to Technic 1 Specification 3/4.3, Changes to ESFAS Functional Units 6.f, 8,a, and 8.b
_ Gentlemen This letter transrrits an application for amendment to Facility Operating License No. HPF-42 for the Wolf Creek Generating Station (WCGS).
l This license amendment request proposes to revise Engineered Safety Features Actuation System (ESFAS) Functional Unit 6.f, Loss of Offsite Power-Start Turbine-Driven Pump, in Technical Specification Tables 3.3-3, 3.3-4,-and 4.3-2 to create separate Functional Units for the analog and digital portions of ti.e ESFAS function associated with starting the turbine-driven auxiliary feedwater
_ pump on a loss of offsite power.
Additionally, this request proposes to revise Engineered Safety Features Actuation System (ESFAS) Functional Unit 8.a, 4 kV Undervoltage Loss of
._ Volt age and 8.b, 4 kV Undervoltage Grid Degrade 1 Voltage, in Technical Specification Table 4.3-2 to add a table notation to clarify that the testing of the time delay relays is performed as part of the CHANNEL ".ALIBRATION.
A Safety Evaluation is pluvided in Attachment I.
A No Significant Hazarda Consider 4ation Determination is provided in Attachment II.
Attachment III is the re'ated Environmental Impact Determination.
Marked up pages are provided
-in Attachmer.L IV (for current Technical Specifications and Bases) and in Attachment V (for Improved Technical Specifications and Bases submitted by the Reference).
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is bcing provided to the designated Kansas State ' Of ficial.
This proposed revision to the WCGS Technical Specifications will be fully implemented within 60 days of formal NRC approval.
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PDR PO. Dox 411/ Durhng'on. KS 66839 / Phone: (316) 364-8831 An [ qual opretturvty En@o v M FHC VET r
ET 98-0002-P ga 2 of 2 It'you have any guestions < >newaning this matter, please contact me at (316) 364-8831,, extension 4034, or-Mr. Michael J. Angus, at extension 4077.
Very truly ours, I,tf^t' i'bl($Vll j
Richar A. Muench
- RAM /jad
. Attachments:
I
- Safety Evaluation II
'No Significant Harards Consideration Determination III - Environmental-Impact Determination IV
- Proposed Current Technical Specification Change V
- Proposed Improved Technical Specification Change cci V. L. Cooper (KDHE), w/a
-W.
D. Johnson (NRC), w/a
'E.
W. Merschoff (NRC), w/a J. F. Ringwald (NRC),-w/a K. H. Thomas (NRC), w/a R
4 STATE OF KANSAS
)
SS COUNTY OF COFFEY
)
Richard A. Muench, of lawful age, being first duly sworn upon oath says that he in Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read'the foregoing document and knows the content thereof; that he has executed that name for and on behalf of said Corpc, ration with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
,M(T By Richard
, Muench Vice Pr sident Engineeritig SUBSCRIBED and sworn to before me this day of f(/M, 199P.
& C.
tb JOUE A.0 ALE Notary P lic
~ NotaryPubic Styteof ar$sas yy Anpt. Expires Jrv40 Expiration Date Ib OO
(
Attachment I to ET 48-0002 Pega 1 of 6 4
s d
ATTACHMENT I SAFETY EVALUATION
Attachm:nt I to ET 90-0002 Pega 2 of 6 I
)
Safety Evaluation Proposed Changes
[
This license amendment request proposes to revise Wolf Creek Generating Station (NCGS)
Technical Specification 3.3, Engineered Safety Features Actuation System (ESFAS) Funct.ional Unit 6.f, Lnss of Offsite Power-Start Turbine-Driven Pump, in Tables ' 3. 3-3, 3.3-4, and 4.3-2 to create separate Functional Unito for the analog. and digital portions of the ESTAS function associated with starting the turbine-driven auxiliary feedwater pump upon loss of offsite power.
Additionally, this request proposes to revise Engineered Safety Features Actuation System (ESFAS) Functional Unit B.a, 4 kV Undervoltage - Loss of Voltage and 0.b, 4 kV Undervoltage Grid Degraded Voltage, in Technical Specification Table 4.3-2 to add a table notation to clarify that the testing of the time delay relays is performed as part of the CHANoEL CALIBRATION.
Background
Loss of Offsite Power Instrumentation and Load Shedder and Emergency Load Sequencer The emergency diesel generators (EDGs) provide a source of emergency power when offsite power is either unavailable or is insufficiently stable to allow safe unit operation.
If a loss of voltage or degraded voltage condition occurs at the 4.16 kV Engineered Safety Features - (EST) buses, undervoltage protection wills a) Trip the 4.16 kV preferred normal and alternate bus feeder breakers to remove che deficient power source to protect the Class 1E equipment from damaget b) Shed all loads from the bus except the Class 1E 480 Vac load centers and centrifugal charging pumps to prepare the buses for re-energization by the load shedder and emergency load sequencer (LSELS); and c) Generate a EDG start signal.
There are two sets of undervoltage protection circuits, one for each 4.16 kV Class 1E system (NB) bus.
Each se' consists of a loss of voltage and degraded volt ge function.
Four poten 1 transformers on each bus provide the necessary input voltages to the protective devices used to perform these functions.
The undervoltage protection circuits are described in the Updated Safety Analysis Report (USAR) Section 8.3.1.1.3.
Four undervoltage relays with an associated time delay are provided for each 4.16kV Class 1E system bus for detecting a loss of bus voltage.
The outputs are combined in a two-out-of-four logic to generate an undervoltage signal if the voltage is below approximately 70%.
A brief time delay is employed to prevent false trips arising from transient undervoltage conditions.
Four degraded voltage bistables with associated time delavs are provided for each 4.16 kV Class lE system bus for detecting a sustained degraded voltage condition.
The four bistable outputs are combined in a two-out-of-four logic to generate a degraded voltage signal if the voltage is below approximately 90% for a predetermined time.
1
-Attcchm:nt I to ET 98-0002 Paga 3 of 6
The BOP ESFAS processes signals from the Solid State Protection Jyst<sm (SSPS),
signal processing equipment,. and plant radiation monitors to actuace certain i
ESF equipment.
There are two redundant trains of Balance of Plant (BOP) -
ESPAb. The redundant trains provide actuation for the motor-dtiven auxiliary feedwater pumps (and repositions automatic valves as required,
!.. e., steam generator blowdown and sample line isolation valves, Essential Se rvice - Water (ESW) supply valves, Condensate Storage Tank (CST) supply valves), containment purge isolation, control room emergency ventilation, and emergency exhaust actuation functions.
A third separation group is provided to actuate the i
turbine-driven euxiliary feedwater (TDAFM) pump and reposition automatic valves (turbine steam supply valves, turbite trip and throttle valve, ESW supply valves, CST supply valve) as required.
Turbine-Driven Auxiliary Feedwater Pump Start on Loss of Offsite Power i
A loss of offsite power (LOP) is indicated by the undervoltage relays i
detecting a loss of voltage on each EST bus, as discussad above.
Upon s,;tisfying the two-out-of-four loss of voltage logic in the LSELS cabinets, LSELS output relays feed the redundant separation groups 1 and 4 BOP-ESTAS cabinets as shown in Figure 1.
The separation groups 1 and 4 BOP-ESFAS cabinets perform several functions, as discussed above, but on a LOP signal theso cabinets perform only two functions, i.e.,
the steam generator blowdown and sample lines are isolated and electrically isolated outputs are provided to the separation group 2 BOP-ESFAS cabinet.
The separation group 2 BOP-ESFAS cabinet-is only assor'iated with the TDAFW pump and is considered to be part of that end device, i.e.,
the TDAFW pump, in the Technical Specificatinns.
On a LOP signal, the turbine steam supply valves (ABHV0005 and ABHV0006) and.the turbine trip and throttle valve (FCHV0312) are opened for the start of the TDAIM pump.
Evaluation-Table 3.3-3
-Table 3.3-3 is revised to create separate Functional Units for the analog and digital portions of the ESFAS function associated with starting the TDAFW pump upon loss of offsite power.
This separation is required to correct the present inconsistency between the operability require.nents imposed in Table
~3.3-3, written only for the digital circuitry,- and the surveillance requirements imposed in Table 4.3-2 which have meaning only for the analog circuitry.
The-analog portion, labeled new Functional. Unit 6.f.1), consists of the same 4kV bus (NB01 and NB02) undervoltage relays specified in Functional Unit 8.at however, differing MODE Applicabilities require a separate line item be added to Table 3.3-3.
The ACTION Statement for new Functional Unit 6.f.1) !s the same as that for Functional Unit 8.a (i. e., ACTION 19) and the same 3.0.4 exception footnote is applied.
The current ACTION Statement.22 for Functional Unit 6.f, with. its 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed outage time (AOT), and the currently specified Total - Number of Channels (2), Channels to Trip (1), and Minimum Channels OPERABLE (2) do not apply to the analog portion with its four channels in a two-out-of-four logic, for which continued operation should be allowed with an inoperable channel as long as it-is tripped within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The digital portion, labeled new Functional Unit 6.f.2),
consists of the output relays from the load shedder and emergency load sequencer (LSELS)
-cabinets and that portion of the BOP-ESFAS separation group 1,2 rnd 4 y
e Attachment I to ET 98-0002 i
Page 4 of 6 I
circuitry associated with the start of the TDAW pump upon a loss of offsite powers - A new ACTION Statement 30 har beca added which recognizes that this
' digital -circuitry it only associated with the TDAFW pump.
As such, the inoperablity of one logic train would be given a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> AOT after which the TDAFW pump would be declared inoperable and ACTION would be taken as required by ' Technical Sp6.:f rication 3.7.1.2.
The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> -AOT is a reasonable 0
i -
restoration time considering the nature of this Functional Unit and the available redundancy.
The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> A0T is also consistent'with that allowed oy i
the current ACTION Statement 72 for Functional = Unit 6.f, as well as the A0T allowed by ACTION Statements for other automatica11v initiated functions L
(e.g.,. F": ION Statement 5.a for Reactor Trip-System Fus.ctional Unit 6.b and ACTION Statement 26 for ESTAS Functional Unit 9).
If both logic trains were
. inoperable, new ACTION Statement 30 would r2 quire that the TDAFW pump be i
immediately declared inoperable.
There would be no requirement to enter j;
Specification 3.0.3-for loss of both logic trains since the only affected end l
device is the TDA W pump _and ACTIONS already exist under Specification 3.7.1.2
?
to address TDAFW pump inoperability. Similar approachos addressing end device OPERABILITY are also used for ESFAS Functional Units 3.c (ACTION Statement 17), 6.a (ACTION Statement 24), and 10 (ACTION Statement 25).-
t
]
- able 3.3-4 i
Tat,le 3.3-4 is revised to create separate Functional Units for the analog and I
i digital' portions of the ESFAS function asoociated with starting tue TDAFW pump i
upon a loss of _ offsite power.
This is necessary since the current
- N.A."
setpoint listings apply only to the digital portion.
The analog portion has a l
- Trip Setpoint and Allowable Value as specified under Functional Unit 8.a.
Table 4.3-2, Functional' Unit 6.f
- Tabic 4.3-2 is revised to create separato Functional Units for the analog and digital portions of the ESTAS function associated with starting the-TDAFW pump upon a loss of offsite power.
This is necessary since only the analog portion of this function 1s subject to a CHANNEL CALIBRATION and a monthly Trip =
Actuating Devace Operational Test (TADOT) can reasonably be performed only on
- the analog portion, since the performance-of a TADOT on the digital'portton at power-is not possible without the use-of jun.pers and lifted sads.
It is proposed that the digital portion only be tested during refueling outages, similar to Functional Unit.6.g, while-ncting that all the BOP-ESFAS actuation
- f logic is tested monthly under Functional. Unit 6.c..
- i Table 4.3-2, Functional Unit 8 i Table e 3-2, Functional Unit 8.a, 4 kV Undervoltage - Loss of-Voltage and 8.b, 4'kV undervoltage - Grid Degraded Voltage, is revised to add a table notation to. clarify that the testing of the time' delay re?.ays is performed as part of the CHANNEL CALIBRATION.
Table 3.3-4, Functional Units 8 a (4kV Undervoltage - Loss of Voltage) and 8.b
[
(4kV-Undervoltage-- Grid Degraded Voltage) specify voltage trip setpoints and
^
the _ associated time delays with tolerances for the relays.
Testing of the
- time a?ays relays-has been performed as part of the 18 month CHANNEL CALIBRATION. The calculated tolerances for the time delay setpoints have been evaluated to _ insure that safety-related systems, subsysteus and components would not _ ber -adversely af fected -- by.- drif t within the -permissible tolerance band..
A review of - data 'obtained from past surveillance testing identified
-=that-the time delay relays-have--remained within the technical specification 5'
-tolerances. The monthly-TADOT is a measurement of the voltage-_secpoint, t-H d
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Attachment-I to ET 98-0002 Page $ of 6 conclusion 4
Based on the above distussions and the No Significant Hazards Consideration Determination presented in Attachment II, the proposed changes do not increase
.the probability of occurrence or the consequences of an accident or malfunction of equipment irnportant to safety previously evaluated in the Updated Safety Analysis Report;1or create a possibility for an accident or malfunction of a different type than any previously evaluated in the safety analyses reports or reduce the margin of safety as defined in the basis for-any technical specification. Therefore,_the proposed changes do not adversely affect or endanger the health or safety of the general public or involve a significant safety har.ard.
(
b
Attachtnent I to ET 98-0002 Page 6 of 6 Auxiliary FeedwaterTuraine Loss-of-Power Actuation Logic c---------------------,
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At t achtnent II to ET 98-0002 Pege 1 of 3 ATTACHMENT II
'4,.dIGNIFICANT HAEARDS CONSIDERATION DETEPF.INATION
=
s Attachment'II to ET'98-0002 4
Pogo 2 of 3 No Significant Hazards Consideration Determination Proposed Changes This license amendment request proposes to revise Wolf Creek Generating Station (WCGS)
Technical. Specification 3.3, Engineered Safety Features
' Actuation System (ESTAS). Functional Unit 6.f, Loss of Offsite Power-Start Turbine-Driven Pump,- in Tables 3.3-3, 3.3-4, and 4.3-2 to create. separate Functional Units for the analog and digital portions of the ESFAS function associated with starting the turbine-driven auxiliary feedwater pump upon loss of.offaite power.
Additianally, this request proposes to revise Engineered Safety Features
. Actuation System (ESFAS) Functional Unit 8.a, 4 kV Undervolsage Loss of -
. Voltage and 8.b, 4 kV Undervoltage Grid Degraded Voltage, in Techn) 1 Specification Table 4.3-2 to add a table--notation to clarify that the te: ing of the time delay relays is performed as part of the CHANNEL CAtlBRATION.
Application of 3tandards The following Standards identified in 10 CFR 50.92 have been usid to determine whether the proposed changes involve a Significant Hazards Consideration.
Each of the identified propoasd changes is evaluated against the three Standards.
Standard I - Involve.a Significcnt Increase in the-Probability or Consequences of en Accident Previously Evaluated Overall protection system.perf ormance will remain within the-. bounds of the previously perf(rmed accident analyses since no hardware changes-are proposed.
The recognition that different OPE'tABILITY and surveillance requirements-apply to ' analog vs.
digital circuitry does not impact any previously1 analyzed accidents.
. The clarifica;!on that. testing of the time. : delay.- relays is performed as part of the CilANNEL CALlBRATION does not impact any previously analyzed events-The proposed change will: not affect-any of-the analysis assumptions. for any of the accidents previously evaluated.
The proposed.-
change does not alter the current method ;or procedures for' meeting the surveillance requirements in Table 4.3-2.
The proposed change will not affect.
the probability of-any event initiatora nor. will the > proposed change af fect tho'abilit.y of any. safety-related equipment to perform its intended function.
There1 will be no degradation-in the performance of nor an increase in-the number of challenges imposed; on safety-related equipment assumed.to function
- during'an accident situation.. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
-standard-II - Create the Possibility of a' New or Different Kind of Accident from any Previously Evaluated
- There are no hardware changes nor are there any_ changes in the method by "Meh any safety-related plant system performs:its safety function.
The ueparation
'of analog and digital portions of Functional Unit 6.f or the clarification of testing of the' tin.s delay relays will'not impact the-.rormal method ~of plant.
operation.
cThe OPERABILITY requirements, ACTION Statement; and surveillance requirer 6nts for theyanalog portion,-new Functional Unit 6.f.1), are identical to thos, of Functional Unit- ' 8.a, ' while -- the requirements for the digital portion, aew
-Functional ~ Unit
-6.f.2),
are consistent with the current technical specifications, other than'the new ACTION Statement 30.provisjons.that defer to the TDAFW pump Specification 3.7.1.2 requirements and the performance of a g
Attachment II to ET 90-0002 Page 3 of 3 TADOT during appropriate plant conditions.
These changes do not change any ESTAS' design standard and are appropriate for digital functions such as ttis.
Testing of the time deleys relays has been performed as part of the 18 month CilANNEL CALIBRATIOt1.
The tolerances for the time delay relays are sufficient to account for relay drift encountered during the 18 month surveillance
=
testing.
The calculated tolerances for the time delay setpoints have been evaluated to insure that safety-related si. stems, subsystems and components would not be adversely affect by drift within the permissible tolerance band.
No new accidsnt scenarios, transient precursors, fai?ure mechanisms, or limiting single failures are introduced as a result of this change.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
Standard III - Involve a Signi ficant Reduction in the Margin of Rafety The proposed change does not affect the acceptance critoria tor any analyrud event.
There will be no effect on the manner in which safety limits or limiting safety system settings are determined nct will there be any effect on those plant systems necessary to assure the accoreplishment of protection functions.
There will be no impact (.n any margin of safety.
Conolusions Dased on the above discussions, it has been determined that the requested technical specification revisions do not involve a significant increase in the probability of consequences of an accident or ett.er adverse conricions over previous ovaluations; or create the possibility of a new or different kind of accident or condition over previous evaluntions; or involve a significant reduction in a margin of safety.
Therefore, the requested license amendment does not invclve a significant hazards consideration.
I l
I
Attachment III to ET 98-0002 Pega 1 of 2 l
ATTACIO4ENT III ENVIRONMENTAL IMPACT DETERMINATION
Attachment III to ET 98-0002 q
9 Page-2-of 2 a
Environmaatal Impact Determination j
1 This license amendment request proposes. to revise Wolf Creek Generating
{
Station' (WCGS) -Technical Specification 3.3, Engineered Safety Featurem
.j Actuation System. (ESFAS) Functional Unit 6.f, Loss Of Offsite Power-Start Turbine-Driven - Pump, in Tables 3.3-3, 3.3-4, and 4.3-2 to create separate.
_ Functional Units for' the-analog and digital portions of the ESFAS function associated with starting the turbine-driven auxiliary feedwater-pump upon loss of offsito power.
' Additional 1/,
this request proposes to.ravise Engineered Safety Features j
Actuation System (ESFAS) Functional ' Unit 8.a, 4 kV Undervoltage Loss of.
t Voltage and'8.b, 4 kV Undervoltage Grid Degraded Voltage, an Technical i
Spec 2fication Table 4.3-2 to add a table notation t.o clarify that the testing i
of the time delay relays is. performed as part of the CHANNEL CALIBRATION.
10 CFR 51.22 (b) specifies the criteria for categorical exclusions from the
-l requirement for a specific environmental assessment per 10 CFR 51.21.
This
-t amendment request meets the criteria specified in. 10 CFR 51. 22 (c) ( 9) a s -.
l specified below (1) the amendment involves no significant hasards consideration j
i 7s demonstrated in Attachment - 11,.
the proposed changer - do not involve. any significant hazards consideration.-
j (ii) there is no significant change in the types or signifloant increasa in
.[
the amounts of any effluents that'may be released offsite
{
None of the proposed changes involves a change to the f acility or. operating procedures that would cause an increase in the amounts of effluents or create new types of eifluents.
(iii) there is _ no : significant increase in individual' or cumulative occupational radiation exposure j.
The proposed changes. relate to differentiating between the analog and digital
-portions of t he -- ES FAS function associated with starting the -- turbine-driven auxiliary feedwater pump.
These changes ~have no relation to occupational radiation exposure, either-individual or cumulative.
Based on the atiove, L 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 10 CFR 51.21 relative to requiring a opccific environmental-assessment by the.
Commission.
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