ML20203L606
| ML20203L606 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/25/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20203L609 | List: |
| References | |
| KMLNRC-86-153, NUDOCS 8608290012 | |
| Download: ML20203L606 (9) | |
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e KANSAS GAS AND ELECTRIC COMPANY f Ttf ELECTS #C COMPANY f August 25, 1986 aoa=no aoa vca WHtt PettiDENT muttram Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 KMLNRC 86-153 Re:
Docket No. STN 50-482 Subj:
Revision to Technical Specification 3/4.8.4
Dear Mr. Denton:
The purpose of this letter is to transmit three original and 40 conformed copies of an amendment to Pacility Operating Licensing No.
NPP-42 for Wolf Creek Generating Station, Unit No.
1.
The application for amendment revises Wolf Creek Generating Station, Unit No.
1, Technical Specification 3/4.8.4, Table 3.8.1 and its associated Bases. The proposed changes to the Technical Specifications are provided in Attachment III.
A complete Safety Evaluation and Significant Hazards Consideration are provided in Attachment I and II respectively.
In acconiance with 10 CPR 50.91, a copy of the application, with attachments is being provided to the designated Kansas State Official.
Enclosed is a check (No. 2364) for the $150.00 application fee required by 10 CPR 170.21.
The proposed re vision to the Wolf Creek Generating Station Technical Specifications will be fully implemented within 30 days of formal Nuclear Regulatory Commission approval.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.
Very truly yours, d
b Glenn L. Koester Vice President - Nuclear GLK see Enclosure i
r Attachments: I-Safety Evaluation I
L II-Significant Hazards Consideration q
III-Proposed Technical Specifics. tion Changes g
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PDR 201 N. Market - Wichita, Kansas - Mail Addrass: PO. Box 208 l Wictuta, Kansas 67201 - Telephone: Area Code (316) 261-6451
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John A. Bailey, of lawful age, being first duly sworn upon oath seys that he is Director-Engineering and Technical Services for Kansas Gas and Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed that same for and on behalf of said Company 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.
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JohnA. Bailey /
Director-Engindering and Technical Services SUBSCRIBED and sworn to before me this M k day of
, 1986.
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e Mr. H. R. Denton August 25, 1986 Attachment I tn KMT.NRC 86-153 Page 1 of 3 SAFETY EVALUATION The proposed amendment would modify Technical Specification 3/4.8.4,
" Containment Penetration Conductor Overcurrent Protective Devices", Table 3 8.1, which provides information on the location, size and equipment protected by the containment penetration conductor overcurrent protective devices, and its associated bases.
This Technical Specification requires the periodic remo val of fuses from their holder and to have a nondestructive resistance measurement test performed on it.
1)
Periodic field measurement of fuse resistance does not pro vide a meaningful assurance on the fault interrupting capability of the fuse.
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2)
Periodic removal of a fuse from its holder for test purposes merely compromises its integrity.
3)
Operational experience.does not indicate that a currer.t limiting fuse ever becomes less protective over its life.
Kansas Gas and Eleletric Company believes that the fuse testing requirement of this Technical Specification is technically ineffective and unnecessary.
Since this change is designed to enhance fuse reliability, Kansas Gas and Electric Company has determined that no unreviewed safety questions exist.
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Mr. H. R. Denton August 25, 1986 Attanhment T to mii.NRC 86-153 Page 2 of 3 PROPOSED CHANGE TO 3.8.4.1 The reference to Table 3.8-1 is removed and in its place is added, "whose circuit limiting fault current exceeds the penetration rating shall be operable."
JUSTIFICATION FOR CHANGE TO 3.8.4.1 Thble 3.8-1 pro vides information on the location, size and equipment protected by the containment penetration conductor overcurrent protective de vices.
Kansas Gas and Electric Company proposes to administratively control the list of containment penetration overcurrent protective de vices at Wolf Creek Generating Station through appropriate plant procedures.
PROPOSED CHANGES TO 4.8.4.1 and 4.8.4.1.a.1.b The reference to Table 3.8-1 is removed and in its place is added, "whose circuit limiting fault current exceeds the penetration rating shall be operable," for 4.8.4.1.
For 4.8.4.1.a.1.b, the reference to Table 3.8-1 is deleted.
JUSTIPICATION FOR CHANGES TO 4.8.4.1 AND 4.8.4.1.a.1.b Same as for 3.8.
4.1 PROPOSED CHANGE
TO 4.8.4.1.a. 3 This entire paragraph is deleted.
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k Mr. H. R. Denton August 25, 1986 j
Attachment I to EMLNRC 86-153 Page 3 of 3 JUSTIFICATION POR CHANGE TO 4.8.4.1.a.3 The NRC staff has concluded, through similar Technical 3pecification chan888
'from.other licensees, that the requirement for measuring fuse resistance.is 4
technically ineffective and unnecessary. The following factors were used in making this determination:
1)
Periodic field m' asurement of fuse resistance does not provide any e
meaningful assurance on the fault interrupting capability of the fuse.
2)
Periodic removal of a fuse from its holder for test purposes merely compromises'its integrity.
3) operational experience does not indicate that a current limiting fuse ever becomes less protective over its life.
Kansas Gas and Electric Company contends that since resistance verification is performed by the vendor during the manufacturing process to assure proper construction - i.e.,
correct amount of fuse elements, correct thickness of elements,
and detection of poor or no solder joints, the operability of fuses should be handled by proper documentation rather than periodic resistance testing.
PROPOSED CHANGE TO BASES FOR 3/4.8.4 This change eliminates the reference to fuses being tested.
It also adds a paragraph stating that a list will be maintained on site.
JUSTIPICATION POR CHANGES TO BASES FOR 3/4.8.a The justification to eliminate fuse testing was already stated for the change to 4.8.4.1.a. 3 7
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ATTACIMENT II 1
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Mr. H. R. Denton Auguat 25, 1986 Attachment II to ' iLNRC 06-153 Page 1 of 1 J
SIGNIFICANT HAZARDS CONSIDERATION The proposed change does not involve a significant hazards consideration because operation of Wolf Creek Generating Station in accordance with this change would not:
1)
Involve a significant increase in the probability or consequences of an accident previously evaluated.
This proposed change teletes the periodic functional (resistance) testing of the fuses for containment penetration conductor overcurrent protection.
Kansas Gas and Electric Company contends that periodic resistance measurement is not a practical means of determining a fuse's condition to assure that its ability to clear a fault has not deteriorated. Rather, the resistance verification is performed by the vendor during the manufacturing process to assure proper construction -
i.e.,
correct amount of fuse elements, correct thickness of elements, and detection of poor or no solder joints.
Therefore, the periodic nondestructive resistance testing of fuses only generates data and is not indicative of performance capability.
2)
Create the possibility of a new or different kind of accident from any accident previously evaluated.
It has been determined that a new or different kind of accident will not occur due to this change.
Periodic removal of a fuse from its holder for test purposes merely compromises its integrity.
3)
Involve a significant reduction in a margin of safety. Operational experience does not indicate that a current limiting fuse e ver becomes less protective over its life, s
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ATTACiffENT III
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