ML20205G189

Safety Evaluation Supporting Amend 123 to License NPF-42

ML20205G189
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Site:	Wolf Creek
Issue date:	03/31/1999
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NUCLEAR REGULATORY COMMISSION T.,... /e WASHINGTON, D.C. 30006 4001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.123 TO FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482 1

1.0 INTRODUCTION

Wolf Creek Generating Station (WCGS) has been operating with Technical Specifications (TS) issued with the original operating license on June 4,1985, as amended from time to time. By application dated May 15,1997, as supplemented by (1) letters in 1998 dated June 30, August 5, August 28, September 24, October 16 October 23, November 24, December 2, December 17, and December 21, and (2) letters in 1999 dated February 4, March 5 (3 letters),

March 25, and March 26, Wo(f Creek Nuclear Operating Corporation (the licensee) proposed to convert the current Technical Specifications (CTS) for both units to the improved Technical Specifications (ITS). The conversion is based upon:

NUREG-1431, " Standard Technical Specifications [STS), Westinghouse Plants,"

a Revision 1, dated April 1995, Commission Final Policy Statement, "NRC Final Policy Statement on Technical Specifications improvements for Nuclear Power Reactors," published on July 22, 1993 (58 FR 39132), and 10 CFR 50.36," Technical Specifications," as amended July is,1995 (60 FR

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36953).

The overall objective of the conversion, consistent with the Final Policy Statement, is to rewrite, reformat, and streamline the TS for WCGS to be in accordance with 10 CFR 50.36, as amended in 1995. The NRC staff acknowledges that, as indicated in the Final Policy Statement, the conversion to the ITS is a voluntary process. Therefore, it is acceptable that the ITS differs from STS, reflecting the current licensing basis for the WCGS.

j in addition to basing the ITS on the STA, the Commission's Final Policy Statement, and the requirements in 10 CFR 50.36, the licensee retained portions of the CTS as a basis for the ITS.

j Plant-specific issues, including design features, requirements, and operating practices, were discussed with the licensee during a series of conference calls and meetings. Meetings were held with the licensee during the weeks of August 17, September 14, and October 12,1998, and on February 12,1999. The meeting summaries were issued on August 28, October 16, and Noverr.ber 6,1998, and on March 30,1999, respectively.

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1 2-Based on these discussions, the licensee has propcsed specifications that were not in the STS -

or the CTS. For proposed specifications that were generic to the STS, the NRC staff requested that the licensee submit the generic revised technical specifications as a proposed change to the STS through the NRC/ Nuclear Energy Institute's Technical Specifications Task Force (TSTF). Proposed changes to the STS, or NUREG-1431, are identified by the acronym TSTF

- and a number as, for example, TSTF-111.. For proposed specifications that were plant-specific, the changes are beyond scope issues for the conversion and are addressed separately in Section 3.G of this Safety Evaluation (SE). The licensee has identified several such generic and plant-specific changes in its application for the ITS conversion.

Cons! stent with the Final Policy Statement, the licensee also proposed transferring some CTS requirements to licensee-controlled documents (such as the updated safety analysis report

- (USAR) for the WCGS, for which changes by licensees are controlled by 10 CFR 50.59 and may be made without prior staff approval). NRC-controlled documents, such as the TS, may i

not be changed by the licensee without prior staff approval. In addition, human factors

' principles wer.e emphasized to add clarity to the CTS requirements being retained in the ITS and to define more clearly the appropriate scope of the ITS. Further, significant changes were proposed to the Bases to make each ITS requirement clearer and easier to understand.

j Since the May 15,1997, application was submitted, Amendment Nos.105 through 122 for WCGS were approved. The licensee has incorporated these amendments as appropriate into i

the ITS.

The NRC staff's evaluation of the application included the supplements listed above that resulted from staff requests for information (RAls) and discussi:ns with the licensee during the NRC review. The staff issued RAls in the letters dated May 22, June 16, June 17, July 7, July 9, July 15, July 17, July 21, August 14, September 3, and October 7,1998, and the meeting nummary issued October 16,1998.

During its review, the NRC staff relied on the Final Policy Statement and the STS as guidance

' for acceptance of CTS requirements into the ITS. This SE provides a summary basis for the NRC staff conclusion that the licensee can develop an ITS for WCGS based on the STS, as modified by plant specific changes, and that the use of the ITS is acceptable for continued operation of WCGS. These plant-specific changes serve to clarify the ITS with respect to the guidance in the Final Policy Statement and STS. The SE also explains the NRC staff's conclusion that the ITS is consistent with the WCGS current licensing basis and the requirements of 10 CFR 50.36.

As stated hereafter, the proposed or improved TS for the WCGS are the ITS, the existing or

' current TS are the CTS, and the improved standard TS, NUREG 1431 for WCGS, are the STS or NUREG-1431. The corresponding TS Bases are ITS Bases, CTS Bases, and STS Bases, respectively.

The Commission's proposed action on the WCGS application for amendment dated May 15,1997, was published in a notice of consideration of issuance of amendment to the WCGS operating license in the Federal Register on October 5,1998 (63 FR 53471), on February 26,1999 (64 FR 9546), and was supplemented for an auditional beyond-scope issue in a notice published in the FederalRegisteron March 1,1999 (64 FR 10028). The licensee's

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letters submitted on March 5, March 25, and March 26,1999, did not contain information outside the scope of the notices that were published. The notices included a list of the issues that were considered beyond the scope of the conversion by the staff (i.e., a change to both the CTS and the STS).' The list in the notices identified more beyond-scope issues than are evaluated in Section 4.G of this SE because either the change was later approved as a TSTF change to the STS, it was withdrawn by the license, or it was later concluded by the staff that the change was not a beyond-scope issue.

2.0 BACKGROUND

Section 182a of the Atomic Energy Act requires that applicants for nuclear power plant operating licenses will state:

[S]uch technical specifications, including information of the amount, kind, and source of special nuclear material required, the place of the use, the specific characteristics of the facility, and such other information as the Commission may, by rule or regulation, deem necessary in order to enable it to find that the i

utilization... of special nuclear material will be in accord with the common defenso and security and will provide adequate protection to the health and safety of the public. Such technical specifications shall be a part of any license issued.

In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TS. In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and the mitigation of accident consequences; the Commission noted that applicants were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity." Statement of Consideration, " Technical Specifications for Facility Licenses; Safety Analysis Reports,"

33 FR 18610 (December 17,1968). Pursuant to 10 CFR 50.36, TS are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls.

For several years, NRC and industry representatives have sought to develop guidelines for improving the content and quality of nuclear power plant TS. On February 6,1987, the Commission issued an interim policy statement on TS improvemen's, " interim Policy Statement on Technical Specification Improvements for Nuclear Power Reactors" (52 FR 3788). During the period from 1989 to 1992, the utility Owners Groups and the NRC staff developed improved STS, such as NUREG-1431 for Westinghouse plants, that would establish models of the Commission's policy for each primary reactor type. In addition, the NRC staff, licensees, and Owners Groups developed gene ic administrative and editorial r#delines in the form of a Writer's Guide" for preparing TS,, which gives greater conside: "an to human factors principles and was used throughout the development of licensee-specific ITS.

In September 1992, the Commission issued NUREG-1431, which was developed using the guidance and criteria contained in the Commission's interim Policy Statement. The STS in NUREG-1431 were established as a model for developing the STS for Westinghouse plants in

r 4-general. The GTS reflect the results of a detailed review of the application of the interim policy statement critene to generic system functions, which were published in a " Split Report" issued to the nuclear steam system supplier (NSSS) owners groups in May 1988. The STS also reflect the results of extensive discussions concerning various drafts of STS, so that the l

pplication of the TS criteria and the Writer's Guide would consistently reflect detailed system configuidions and operating characteristics for all NSSS designs. As such, the generic Bases presented in NUREG 1431 provide an abundance of information regarding the extent to which the STS present requirements that are necessary to protect public health and safety. The STS In NUREG-1431 apply to the WCGS.

On July 22,1993, the Commission issued its Final Policy Statement, expressing the view that satisfying the guidance in the policy statement also satisfies Section 182a of the Act and 10 CFR 50,36 (58 FR 39132). The Final Policy Statement described the safety benefits of the STS, and encouraged licensees to use the STS as the basis for plant-specific TS amendments, 1

and for complete conversions to ITS bated on the STS. Further, the Final Policy Statement gave guidance for evaluating the required scope of the TS and defined the guidance criteria to be used in determining which of the LCOs and associated surveillances should remain in the TS. The Commission noted that, in allowing certain items to be relocated to licensee-controlled documents while requiring that other items be retained in the TS, it was adopting the qualitative standard enunciated by the Atomic Safety and Licensing Appeal Board in Portland Genera / Electric Co. (Trojan Nuclear Plant), ALAB-531,9 NRC 263,273 (1979). There, the Appeal Board observed:

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[T]here is nenher a statutory nor a regulatory requirement that every operational detail set forth in an applicant's safety analysis report (or equivalent) be subject to a technical specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval. Rather, as best we can discern it, the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.

By this approach, existing LCO requirements that fall within or satisfy any of the criteria in the Final Policy Statement should be retained in the TS; those LCO requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. The Commission codified the four criteria in 10 CFR 50.36 (60 FR 36953, July 19,1995). The four criteria are as follows:

Criterion 1 Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

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5-Criterion 2 A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3 A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challonge to the integrity of a fission j

product barrier.

Criterion 4 4

A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Section 4.0 of this SE explains the NRC staff's conclusion that the conversion of the CTS to the ITS based on STS, as modified by plant-specific changes, is consistent with the WCGS current licensing basis, and the requirements and guidance of the Commission's Final Policy Statement and 10 CFR 50.36.

3.0 UTILITIES JOINT EFFORT 1

This conversion is a toint effort in concert with three other utilities: Pacific Gas & Electric Company for DiaF Canyon Power Plant, Units 1 and 2 (Docket Nos. 50-275 and 50-323); TU Electric for Corr i Peak Steam Electric Station, Units 1 and 2 (Docket Nos. 50-445 and 50-446); and l Jectric Company for Callaway Plant (Docket No. 50-483). It is a goal of the four utilitit a raake the ITS for their plants as similar as possible. This group of four utilities was designated the four loop owners group (FLOG).

This joint effort includes a common methodology for the licensees in marking-up the CTS, STS, and STS Bases, that has been accepted by the sta'f. This common methodology is discussed at the end of Enclosure 2," Mark-Up of Current TS"; Enclosure 5A," Mark-Up of NUREG-1431 Specifications"; and Enclosure SB," Mark-Up of NUREG-1431 Bases," for each of the 14 separate ITS sections that were submitted with the licensee's application. For each of the ITS sections, the following enclosures are included:, " Cross-Reference Tables," the cross-reference table connecting each CTS specification (i.e., LCO. required action, or SR) to the associated ITS spocification, sorted by both CTS and ITS specifications.

Enclosures 3A and 3B," Description of Changes t^ Current TS" and " Conversion Comparison Table," the description of the chariges to the CTS section and the comparison table showing which plants (of the four licensees in the joint effort) that each change to the CTS applios to.

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' Enclosure 4, "No Significant Hazards Considerations," the no significant hazards consideration (NSHC) of 10 CFR 50.91 for the changes to the CTS with generic NSHCs for administrative, more restrictive, to be relocated, and to be moved-l out-of-CTS changes, and individual NSHCs for less restrictive changes.

j Enclosures 6A and 6B, " Differences From NUREG-1431" and " Conversion

- Comparison Table," the descriptions of the differences from NUREG-1431 Specifications and the comparison table showing which plants (of the four '

licensees in the joint effort) that each difference to the STS applies to.

The common methodology includes the convention that, if the words in a CTS specification are not the same as the words in the ITS specification, but the CTS words have the same meaning or have the same requirements as the words in the ITS specification, then the licensees do not J

have to indicate or describe a change to the CTS. In general, only technical changes have

. been identified; however, some non-technical changes have also been 1(entified when the changes cannot easily be determined. The portion of any specification which is being deleted is struck through (i.e., the deletion is annotated using the strike-out feature of the word processing i

computer program or crossed out by hand). Any text being added to a specification is shown by shading the text, placing a circle around the new text, or by writing the text in by hand. The text being struck through or added is shown in the marked-up CTS and STS pages in Enclosures 2 (CTS pages) and 5 (STS and STS Bases pages) for each ITS section attached to i

the application. Another convention of the common methodology is that the technical justifications for the less restrictive changes are included in the NSHCs.

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If as part of the licensee's responses to RAls from the staff there were corrections to the licensee's proposed changes to the CTS and STS, the licensee submitted the appropriate corrected pages for Enclosures 1 through 6 for the associated CTS /ITS section.

The changes to the CTS are identified by change numbers (CNs) that are listed in Enclosure 3 and are determined by the convention discussed at the end of Enclosure 2. The change number is of the form 4-13-A, where the first number is a prefix number (i.e., the 4 of 4-13-A) assigned to each specification (or group of similar specifications) within an CTS section, as for example CTS 3/4.6, Containment Systems, such that it refers to the same specification for each utility regardless of the actual specification number in their individual plant CTS. The second i

number (i.e., the 13 of 4-13-A) identifies the change within the given specification or group of specifications (these are changes having the same prefix number); however, the second number does not denote the sequence of the changes within the given specification or group of specifications. For example, the change 4-03-X may not follow change 4-02-X in the CTS i

specification, or group of specifications, denoted by the prefix 4. The changes through the CTS specifications may not be in the same sequence as given by the second number. The letter suffix (i.e., the A of 4-13-A) identifies one of the following types of change:

"A" for administrative changes.

"M" for more restrictive changes.

"LS" or "TR" for CTS requirements that are relaxed or eliminated, or for which new operational flexibility is added to the ITS compared to the CTS. (LS changes are individual less restrictive changes and TR changes are licensee-

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7-identified groupings of less restrictive changes, as discussed in Section 3.C of the SE.) ~

"R" for changes to relocate CTS requirements, which do not meet the 10 CFR e

50.36, as amended, criteria, to appropriate licensee-controlled documents.

"LG" for CTS descriptions and details, not requirements, that are relocated to appropriate licensee-controlled documents.

1 For the case where the same change to the CTS is being proposed by more than one of the licensees, then these licensees use the same change number to identify the change and the other licensees, not proposing the change, list the change number but state "not applicable" in 4

the description of the change. For example, change 01-07-LG for ITS 3/4.2 is a change to relocate surveillance frequencies to licensce-controlled documents and is proposed by all the

. licensees (see Enclosure 3B of the licensee's application). For change 01-03-LG in the same ITS section, only the licensee is proposing the change and this change is "not applicable" to the other licensees. There may be cases, where most of the identified changes for an ITS section may not be applicable to a specific licensee because these changes do not need to be made to J

the CTS for that licensee.

The licensee may have more than one less-restrictive change in the same ITS section with the same "LS" number or "TR" number. Because these "LS" and "TR" numbers refer to specific NSHCs provided in Enclosure 4 to the application for an ITS section, these less-restrictive

- changes are the not same change, but they are the same type of "LS' or "TR" change and have j

the same NSHC.

l As a result of differences between the individual CTS for the FLOG, and because of changes to the CTS that may occur after the initial assignments of change identifiers, the change numbers may not appear sequentially in the CTS markup. Also, the second number is assigned sequentially independent of the type of change that is identified. Therefore, change 4-12-M may be listed before 4-13-A and after 4-11-LG.

The type of change also identifies the type of NSHC provided in Enclosure 4. The NSHCs for the A, M, R, and LG changes are generic and only one NSHC is provided for each of these types of changes in Enclosure 4. The NSHCs for LS and TR changes are individual and a suffix number is assigned for each such change, for example,4-13-LS-1 or 4-13-TR-2, where the first LS change or second TR change is identified. The change number listed in Enclosure 3 that was assigned to these LS and TR would also include the suffix number, as change 4 LS-1 or change 4-13-TR 2. These change numbers are included in the tables attached to this SE to identify the changes described in the tables. There are tables for each type of change listed above.

4.0 EVALUATION The NRC staff's ITS review evaluates changes to CTS that fall into five categories defined by the licensee and includes an evaluation where appropriate of whether existing regulatory requirements are adequate for controlling future changes to requirements removed from the j

CTS and placed in licensee controlled documents.

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! The NRC staff review also identified the need for clarifications and additions to the application i

in order to establish an appropriate regulatory basis for translation of CTS requirements into the ITS. Each change proposed in the amendment request is identified as either (1) a description of change (DOC), identified by a change number (CN), to the CTS, or (2) a difference from NUREG-1431, which is a justification for deviation (JFD) from the STS. The NRC staff comments were documented as RAls and issued in letters or meeting summaries to the licensee. These comments were intended to clarify the licensee's basis for translating the CTS j

requirements into ITS. The NRC staff finds that the licensee's submittals including responses to RAls provide sufficient detail to allow the staff to reach a conclusion regarding the adequacy of the licensee's proposed changes to the CTS.

The license amendment application was organized such that changes were included in each of the following CTS change categories, as appropriate:

(1)

Administrative Changes, (A), i.e., non-technical changes in the presentation of CTS requirements; (2)

Technical Changes - More Restrictive, (M), i.e., new or additional TS requirements; (3)

Technical Changes - Less Restrictive (specific), (LS and TR), i.e., changes, deletions, and relaxations of CTS requirements; (4)

Technical Changes - Less Restrictive (generic), (LG), i.e., deletion of CTS details by the relocation of information and requirements from existing specifications (that are otherwise being retained) to licensee-controlled documents, including the ITS Bases; and (5)

Relocated Technical Specifications, (R), i.e., relaxations in which whole CTS

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specifications (the LCO, and associated action and SR) are removed from the CTS (an NRC-controlled document) and placed in licensee-controlled documents.

The changes that are in the ITS conversion for the WCGS for each of the above categories are listed in the following five tables attached to this SE:

i Table A of Administrative Changes to Current Technical Specifications Table M of More Restrictive Changes to Current Technical Specifications Table LS of Less Restrictive Changes to Current Technical Specifications (that also includes the TR changes)

Table LG of Details Relocated from Current Technical Specifications Table R of Relocated Current Technical Specifications These tables provide a summary description of the proposed changes to the CTS, the specific CTS that are being changed, and the specific ITS that incorporate the change. If the table only lists a CTS LCO, as for example LCO 3.4.1, then the CTS being changed is the specific LCO 3.4.1 thr' is the entirety of the specification for LCO 3.4.1 (i.e., LCO, actions, and SRs) is being changed. However, if an action or an SR is listed, then only the specific action or SR is being

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changed (e.g., LCO 3.4.i, Action a or SR 4.4.1.2). The same is true for an ITS LCO, action or SR, except the ITS is incorporating the change. The tables are only meant to summarize the changes being made to the CTS. The details, as to what the actual changes are and how they

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are being made to the CTS or ITS, are only provided in the licensee's application and supplementalletters.

These general categories of changes to the licensee's CTS requirements and STS differences are as follows:

A.

Administrative Changes Administrative (non-technical) changes are intended to incorporate human factors principles into the form and structure of the ITS so that plant operations personnel can use them more easily. Thcse changes are editorial in nature or involve the reorganization or reformatting of i

CTS requirements without affecting technical content or operational restrictions. Every section l

of the ITS reflects this type of change. In order to ensure consistency, the NRC staff and the 3

licensee have used the STS as guidance to reformat and make other administrative changes.

i Among the changes proposed by the licensee and found acceptable by the NRC staff are:

j (1) providing the appropriate numbers, etc., for STS bracketed information (information that must be supplied on a plant-specific basis and that may change j

l from plant to plant);

(2) identifying plant specific wording for system names, etc.;

(3)'

changing the wording of specification titles in STS to conform to existing plant practices; (4) splitting up requirements currently grouped under a single current specification to more appropriate locations in two or more specifications of ITS; (5) combining related requirements currently presented in separate specifications of 3

j the CTS into a single specification of ITS; c

(6) presentation changes that involve rewording or reformatting for clarity (including moving an existing requirement to another location within the TS) but which do not involve a change in requir?ments; (7) wording changes and additions cut are consistent with CTS interpretation and practice, and that more clearly or explicitly state existing requirements;

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(8) deletion of TS whose applicability has expired; and (9) deletion of redundant TS requirements that exist elsewhere in the TS or in the i

regulations (e.g.,10 CFR 50.73).

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Table A lists the administrative changes to the CTS. Organized by CTS sections, the table provides a summary description of the administrative changes, the CN, and the CTS and ITS references. The NRC staff reviewed all of the administrative changes proposed by tha licensee

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and finds them acceptable because they are compatible with the Writer's Guide and the STS, do not result in any change in operating requirements, and are consistent with the j

Commission's regulations.

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B.

Technical Changes - More Restrictive The licensee, in electing to implement the specifications of the STS, proposed a number of j

requirements more restrictive than those in the CTS. The ITS requirements in this category l

include requirements that are either new, more conservative than corresponding requirements in the CTS, or that have additional restrictions that are not in the CTS but are in the STS.

Examples of more restrictive requirements are placing an LCO on plant equipment which is not required by the CTS to be operable, more restrictive requirements to restore inoperable equipment, and more restrictive SRs. Table M lists the more restrictive changes to the CTS.~

Organized by CTS section, the table provides a summary description of the more restrictive changes, the CN, and the CTS and ITS references. The NRC staff reviewed the more l

' changes are additional restrictions on plant operation that enhance safety.

restrictive changes proposed by the licensee and finds them acceptable because these 1

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Technical Changes - Less Restrictive (Specific) l Less restrictive requirements include changes, deletions and relaxations to portions of the CTS

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requirements that are not being retained in ITS. When requirements have been shown to give 1

little or no safety benefit, their removal from the TS may be appropriate. In most cases, l

relaxations previously granted to individual plants on a plant specific basis were the result of (1) i generic NRC actions, (2) new NRC staff positions that have evolved from technological 1

i advancements and operating experienue, or (3) resolution of the Owners Groups comments on the STS. The NRC staff reviewed generic relaxations contained in the STS and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. The WCGS design was also reviewed to determine if the specific design basis and i

licensing basis for the WCGS are consistent with the technical basis for the model requirements i~

in the STS, and thus provide a basis for the ITS.

' A significant number of less restrictive changes to the CTS were categorized based upon the type of less restrictive change to the CTS requirements. These categories are as follows:

l Category 1 Relaxation of CTS LCO Applicability L

Category 11 Relaxation of CTS Surveillance Frequency l

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Relaxation of CTS Action Requirements CategoryIV -

Relaxation of CTS Required Action Completion Time i

Category V Relaxation of CTS Surveillance Requirement Acceptance Criteria i

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Relaxation of CTS Action Entry to Perform SRs Category Vil -

Deletion of Requirements Contained in Regulations and of Explicit Post Maintenance SRs Category Vill-Relaxation of LCO Requirements The following discussions address why various specifications within each of these eight categories of information or specific requirements are not required to be included in ITS.

Relaxation of CTS LCO Aoolicability (Category l}

Reactor operating conditions are used in the CTS to define when the LCO is required to be met. The LCO applicabilities can be specifically defined terms of reactor modes of operation (i.e., the reador modes defined in the TS, and other operating conditions as when irradiated fuel is being moved). The applicabilities can also be more general.

Depending on the circumstances, CTS may require that the LCO be maintained within limits in "all modes" or "any operating mode." However, generalized applicability l

conditions are not contained in the STS, therefore the ITS eliminate the CTS requirements such as "all modes" or "any operating mode," replacing them with ITS defined modes or applicable conditions that are consistent with the application of the plant safety analysis assumptions for operability of the required features.

In another application of this type of change, CTS requirements may be eliminated during conditions for which the safety function of the specified safety system is met because the feature is performing its intended safety function. Deleting applicability requirements that are indeterminate or which are inconsistent with application of accident analyses assumptions is acceptable because when LCOs cannot be met, the TS can be satisfied by exiting the applicability thus taking the plant out of the conditions q

that require the safety system to be operable. These changes are consistent with the STS, and changes specified as Category I are acceptable.

l Relaxation of CTS Surveillance Freauency (Category ll)

CTS and ITS surveillance frequencies specify time interval requirements for performing surveillance testing. Increasing the time interval between surveillance tests in the ITS results in decreased equipment unavailability because of testing. In general, the STS contain surveillance frequencies that are consistent with industry practice or industry standards for achieving acceptable levels of equipment reliability. Adopting testing practices specified in the STS is acceptable based on similar design, like-component testing for the system application, and the availability of other TS requirements which provide regular checks to ensure limits are met.

Reduced testing can enhance safety because it reduces system unavailability from testing; in tum, reliability of the affected structure, system or component should remain constant, or may increase because of fewer testing challenges to the system. Reduced testing is acceptable where operating experience, industry practice, or industry standards, such as manufacturers' recommendations, have shown that components

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usually pass the surveillance when performed at the specified interval. Therefore, the frequency is acceptable from a reliability standpoint. Surveillance frequency changes to incorporate alternate train testing has been shown to be acceptable where other qualitative or quantitative test requirements are required which are established predictors of system performance (e.g., a 31-day air flow test is an indicator that positive i

pressure in a controlled space will be maintained because the test would use the same i

fans as the less frequent ITS 36-month pressurization test and industry experience shows that components usually pass the pressurization test). Additionally, surveillance frequency relaxation can be based on staff-approved topical reports. The NRC staff has accepted topical report analyses that bound the plant-specific design and component reliability assumptions. These changes are consistent with the STS, and changes specified as Category ll are acceptable.

Relaxation of CTS Action Reauirements (Categorylil)

Upon discovery of a failure to meet an LCO, the STS specify required actions to complete for the associated TS conditions. Required actions of the associated conditions are used to establish remedial measures that must be taken in response to the degraded conditions. Adopting required actions from the STS is acceptable because STS-required actions take into account the operability status of redundant systems of TS-required features, the capacity and capability of the remaining features, and the compensatory attributes of the required actions as compared to the LCO requirements. In conjunction with the relaxation of the applicability of several CTS specifications (Type I changes), the associated action requirements to exit the applicability are also relaxed. Such relaxations of action requirements are acceptable because they are commensurate with industry standards for reductions in thermal power in an orderly fashion without compromising safe operation of the plant. Therefore, changes falling within Category lli are acceptable.

Relaxation of CTS Reauired Action Comoletion Time (Category IV)

]

' Upon discovery of a failure to meet an LCO, the STS specify times for completing required actions of the associated TS conditions. Required actions of the associated conditions are used to establish remedial measures that must be taken within specified completion times. These times define limits during which operation in a degraded condition is permitted. Adopting completion times from the STS is acceptable because completion times take into account the operability status of the redundant systems of TS-required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a design basis accident (OBA) occurring during the repair period. Therefore, changes falling within Category IV are acceptable.

Relaxation of CTS Surveillance Reauirement Acceptance Criteria (Category V)

The CTS require safety systems to be tested and verified operable prior to entering applicable conditions. The ITS provide the additional requirement to verify operability by

- actual or test conditions. Adopting the STS allowance for " actual" conditions is acceptable because TS-required features cannot distinguish between an " actual" signal

+

or a " test" signal. Category V also includes changes to CTS requirements that are

. replaced in the ITS with separate and distinct testing requirements which, when combined, include operability verification of all TS-required components for the features specified in the CTS. Adopting the format preference in the STS is acceptable because SRs that remain include testing of all previous features required to be verified operable.

I i

The identification of the specific signal for safety system testing may be listed in the CTS; however, this detail is not necessary for inclusion in the TS to ensure operability of the associated systems. This detail will be relocated to the ITS Bases where changes are controlled by the ITS Bases control program in ITS 5.5.14. The ITS require that changes to the Bases may be without prior staff approval only if the changes meet the criteria in 10 CFR 50.59, which is the same criteria used to control changes to the description of the plant in the WCGS USAR. The ITS Bases is an acceptable licensee-I controlled document for this detail.

d These changes are either consistent with the STS or are acceptable'to be relocated to i

the ITS Bases. Therefore, changes falling in Category V are acceptable.

I Relaxation of CTS Action Entry to Perform SRs (Category VI) l The STS allows an instrument channel to be placed in an inoperable status solely for the performance of required surveillance testing, without entering the associated conditions and required actions, provided the associated function maintains trip capability. This allowance is generally six hours, during which time the functional capability is maintained. This relaxation is in accordance with approved topical reports. Adopting this STS approach to action entry during surveillance testing is acceptable because it takes into account the capability of the specified function, time for required test completion, and the extremely low probability of a design basis event occurring during the test period. Therefore, changes falling within Category VI are acceptable.

Deletion of Reauirements Contained in Reaulations and of Exoticit Post Maintenance 283 (Category Vil)

Some requirements contained in the regulations have also been included in plant TS. If these requirements are in the regulations, they will apply to the licensee's operation of the plant whether or not they are in the TS. Therefore, these requirements do not need to be included in the TS. Also, plant TS have included specific requirements on performing surveillances prior to retuming equipment or systems to service following maintenance, repair or replacement. Explicit post-maintenance TS surveillance requirements do not have to be included in the TS because these requirements are adequately addressed by the definition of operability in the CTS and ITS, and by the licensee's administrative post-maintenance programs govemed by plant procedures.

These deletions are acceptable because they are not important to ensure the ITS's effectiveness. In addition, omitting this information from the ITS is acceptable because it will continue to be contained in appropriate station procedures required by ITS 5.4.1.

Therefore, changes falling within Category Vil are acceptable.

_ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l Relaxation of LCO Reauirements (Category Vill) l The CTS provide lists of acceptable conditions that may be used to satisfy LCO requirements. The ITS reflect the STS approach to provide LCO requirements that specify the protective limit that is required to meet safety analysis assumptions for required features. The protective limits replace the lists of specific devices previously found to be acceptable to the NRC staff for meeting the LCOs. The ITS changes provide the same degree of protection required by the safety analysis and provide flexibility for meeting limits without adversely affecting operations because equivalent features are required to be operable. These changes are consistent with the STS and changes specified as Category Vill are acceptable.

The licensee identified "LS" and "TR" less restrictive changes to the CTS. The three sets of TR changes (i.e., TR-1, TR-2, and TR-3) are three groups of similar less restrictive changes similar j

to the categories discussed above. TR-1 changes are Category V changes to the CTS that, j

consistent to the STS, allow the use of an actual signal to satisfy SRs and relocate the specific signals to the ITS Bases. TR-2 changes are Category Vil changes to the CTS that, consistent with the STS, delete the requirements for special reports because the requirement is sufficiently addressed in the regulations (e.g.,10 CFR 50.73). ' TR-3 changes are also Category Vil changes to the CTS that, consistent with the STS, delete the statement that testing must be performed on systems or equipment following maintenance because specific post maintenance test requirements are not necessary to be stated in the TS. The LS changes are individual less restrictive changes to the CTS.

Table LS lists the less restrictive changes to the CTS. Organized by CTS section, the table provides a summary description of the less restrictive changes (the LS-type and TR-type changes), the CN, and the CTS and ITS references. The table also provides the applicable change categories, as discussed above. The above less restrictive change categories are listed at the bottom of each page of Table LS.

If a change category does not apply to a less restrictive change, the word " unique" is specified in the table for that chance and an evaluation of.the change is provided below. Each evaluation below is preceded by the ITS section or specification and the CN identifier (e.g., LS-1 or TR-1) associated with the change. All of these changes to the CTS are consistent with the STS and, i

therefore, are not beyond-scope issues for the ITS conversion. The changes that are beyond-scope issues for the ITS conversion are' addressed in Section 3.G of this SE.

CTS Section 3.0 LS-2 The STS LCO 3.0.5 is proposed to be added to the ITS to provide an exception to ITS LCO 3.0.2. ITS LCO 3.0.2 states that, upon discovery of a failure to met an LCO (i.e.,

equipment is inoperable), the required actions of the LCO shall be met. The LCO 3.0.5 exception is for instances where restoration of the inoperable equipment to an operable status could not be performed while continuing to comply with the required actions for an LCO. Many LCO actions require an inoperable component to be removed from service and an exception to these actions is necessary to allow the performance of SRs to either demonstrate the operability of the equipment being returned to service or to demonstrate the operability of other equipment.

l 15-i LCO 3.0.5 is necessary to establish an allowance that is not formally recognized in the CTS. Without this allowance, certain components could not be restored to operable status and a station shutdown would ensue. Clearly, it is not the intent or desire that the TS preclude the return to service of a component to confirm its operability. This -

allowance is deemed to represent a more stable, safe operation than requiring a stat!on shutdown to complete the restoration and confirmatory testing. The time during which the equipment is returned to service is very small, therefore, the probability of an accident during that time period is also very small and insignificant. Therefore, the proposed STS LCO 3.0.5 is acceptable.

CTS Specification 3.3

)

l LS-8 The proposed change will add the option, not in the CTS, to reduce power to less than i

P-7 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the case where the number of operable channels is less than those required. The new footnote c is added to the applicable modes for the functions so that the applicable modes are consistent with the added option. The change reflects a revision to CTS Action 6. If the requirements in the action are not met, LCO 3.0.3 would be entered. This action is proposed to be revised to state that, if the action requirements are not met, thermal power must be reduced to below the P-7 interlock setpoint within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Most of the functional units that have Action 6, the pressurizer pressure - low, pressurizer water level - high, reactor coolant flow - low, two loops (above P-7 and below P-8), RCP undervoltage, and RCP underfrequency, are automatically blocked below P-7 and an applicability note has been added accordingly.

The reactor coolant flow - low (single loop) reactor trip function does not have to be operable below the P-8 setpoint; however, the action must take the plant below the P-7 setpoint, if an inoperable channel is not tripped within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, due to the shared components between this function and the reactor coolant flow - low (two loops) trip function. The proposed changes are acceptable because the ITS actions and applicabilities are consistent with the safety analysis assumptions which require operability of these functions above the P-7 interlock.

LS-11 The proposed change will revise CTS applicability modes by adding new notes a and b in Table 3.3-2, for functions #4.a.2, #4.b, #4.c, #4.d, #4.e, #5.a, and #5.b. A new note a is proposed to be added for the steam line isolat!on functional units to state that the LCO requirements are not applicable in Modes 2 and 3 when the main steam isolation valves (MSIVs) are closed. Note b is proposed to be added for the feedwater isolation and turbine trip function units to state that the LCO requirements are not applicable when all main feedwater isolation valves (MFIVs) are closed. When these valves are closed, they are performing their safety function. These safety functions are accomplished when the associated valves are closed, whether that closure is as a result of automatic isolation circuitry or operator action. Operability requirements on actuation circuitry are not applicable if the valves are closed. The proposed change will not affect the ability of any safety related equipment to perform its intended function. There 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.

The proposed change is acceptable because the change will not affect any of the analysis assumptions for any of the accidents previously evaluated.

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16-LS-31 The proposed change to CTS Action 19 requirements in Table 3.3 3 reflect applying STS LCO 3.3.5 (including the LCO conditions) for the loss of power functional unit. The relaxation would apply to situations of multiple inoperable channels on one bus and for failure to place an inoperable channel in trip within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in Modes 1 to 4. These situations currently require entry into LCO 3.0.3 because they are outside the scope of the CTS Action 19. Following the conditions proposed for the ITS, there would be instead an immediate entry from ITS LCO 3.3.5, Condition B, into ITS LCO 3.8.1, Condition F, and a 12-hour completion time to repair equipment. The 12-hour restoration time is a relaxation of the CTS action instead of starting to shut down the plant. ITS LCO 3.3.5, Condition B, provides an action for two or more inoperable channels on one or more buses. In this condition, the TS require declaring the supported feature, the load shedder and emergency load sequencer (LSELS) in LCO 3.8.1 or LCO 3.8.2, inoperable immediately. Because the loss of voltage and degraded voltage instrumentation provide input signals to the LSELS, which use the signals to initiate actions to shed loads and start emergency diesel generators affected by the loss of voltage condition. ITS LCO 3.3.5, Condition A, relaxes the CTS action times for one inoperable channel to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and for surveillance test intervals to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The specified completion times for repair and test are acceptable because the functions remains fully operable on every bus.

LS-40 The proposed change deletes the requirement in Table 4.3-1, by applying footnote 10 for Functions 14 and 15, to verify the setpoint during the quarterly trip actuating device operational test (TADOT) for reactor coolant pump (RCP) underfrequency and undervoltage. The licensee stated that the setpoint is adequately confirmed during the 18-month channel calibration. Because the licensee confirmed that setpoint verification testing during the 18-month channel calibration is adequate to ensure instrument sensors remain operable between testing, the proposed change is acceptable.

LS-43 The proposed change to CTS SRs 4.3.3.5.1 and 4.3.3.6 will limit the channel check to each required instrument channel"that is normally energized." The revised SR will exempt instrumentation that is not normally energized. The CTS require that channel calibrations are performed for instrumentation used in the post accident monitoring and remote shutdown systems on an 18-month basis. Some of these instruments are then de-energized and remain in this state until re-energized for use in the management of plant events or for the performance of the channel checks. Channel checks are performed more frequently than channel calibrations for the purpose of detecting gross channel failures or excessive drift of one channel relative to other channels monitoring the same process variable. During the period that the channel is de-energized, it is not subject to the failure mechanisms or conditions that typically lead to instrument failure or excessive drift. Because de-energized channels are not subjected to the same failure mechanisms as energized channels, it is acceptable to exempt instrumentation not normally energized from the performance of the periodic channel checks.

CTS Specification 3.4 LS-2 The proposed change adds an additional specific relaxation to allow the use of an operating RCS loop in lieu of an operating residua! heat removal (RHR) loop in Mode 5 during planned heatup in preparation to enter Mode 4. The proposed change will relax y

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CTS LCO 3.4.1.4.1, footnote ", by allowing th' use of an operating RCS loop in lieu of s

l an operatbg RHR loop in Mode 5 during planned heatup in preparation to enter Mode 4.

The primary functions of the operating RHR loop in Mode 5 are to remove decay heat

{

and to prevent boron stratification in the RCS. These functions can also be performed j

by an operating RCS loop which is a normal method of accomplishing these same j

functions when in Mode 4. In addition, at least one RHR loop must remain operable j

during the transition to Mode 4. The proposed change does not reduce the heat removal / boron mixing capability or system reliabilit/ when the RCS loop is performing these functions. Based on the ability of these functions to be performed by an operatir g i

RCS loop, the proposed change is acceptable.

s l

LS-12 The proposed change will delete the requirement in CTS SRs 4.4.6.2.1.a and j

4.4.6.2.1.b to monitor the RCS leakage detection system once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Because i

the.lTS LCO 3.4.15 requires that a channel check be performed on the containment l

radioactivity monitor channels on the same frequency as the CTS and the containment j

sump level and flow monitoring system and the condensate flow monitor are i

continuously monitored from the control room via available alarms and indications,'such i

monitoring is unnecessary. Leak detection provides information that may indicate i

degradation of the RCS pressure boundary; however, the RCS leaksge detection l

system is not credited in any safety analyses. Nevertheless, the continued operation of l

the leakage detection function is assured by the diverse means of leakage detection i

that have been provided within the system and by the requirement that a RCS water j

inventory balance be performed every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Because leakage information is available from diverse sources, which are checked by an RCS water inventory balere, j

the delet;on of the surveillance does not negatively impact RCS leak detection and ths l

proposed change is acceptable.

1

- LS-14 The proposed chnge will delete the requirement in CTS SR 4.4.6.2.1.e for monitoring the reactor head flange leakoff system at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Flange leakoff does j.

not provide an indicator of pressure boundary integrity. Reactor head leakage, which is collected in the reactor coolant drain tank, is quantified as identified leakage which is

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determined by periormenco of a RCS water inventory balance and limited to a maximum i

value by the ITS. The initial RCS water inventory balance is required within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following RCS steady state operation and every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter. The flange leakage by itself is not an initial assumption in the accident analyses. Because reactor head flange leakage is accounted for by RCS inventory balance and can be detected by the various leakage monitoring systems, the proposed change is acceptable.

LS-15 The proposed change will relax the criteria, in CTS SR 4.4.F 2.2.b, for PlV testing following operation in Mode 5. The criterion that testing be performed after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> was extended to 7 days. Allowing additional time in Mode 5 before testing is required

- will have little or no impact on the pressure retaining capability of the isolation valves, and the proposed change is acceptable.

LS-20 The proposed change will revise CTS SR 4.4.9.3.1.a to allow performance of the COT on the PORV actuation channels within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Mode 4. Previously, such testing was required to be performed prior to entry into the mode. The proposed change will not affect the ability of the PORVs to perform their intended function as part J

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- ci the cold overpressure mitigation system because the channel calibration is still required to be maintained current. In addition, entry into Mode 4 (from Mode 3) occurs at 350*F at whch time the RHR system is normally in operation providing relief capability via the RHR relief valves. Because the propeaed change will not affect PORV performance and the RHR relief valves would be avacable, the proposed change is acceptable.

LS-22 The proposed change will relax the CTS by requiring only two RCS loops to be operable wl Jn the control rod sy' stem is capable of rod withdrawal and one RCS loop to be operable when the control rod system is not capable of rod withdrawa!. The LCO and Action b of Specification 3.4.1.2, " Reactor Coolant System, Hot Standby," would be revised to require that two reactor coolant loops be operable. Loop operation requirements would also be revised to be contingent on rod control system status. The requirement to have a third operable reactor coolant loop would be deleted. The decay heat removal in Mode 3 is sufficiently low that a single RCS loop with one RCP running is adequate to remove core decay heat. /. second RCS loop er.sures redundant capability for decay heat removal. When the rod control system is capable of rod withdrawal, two loops must be in operation to ensure accident analysis assumptions are satisfied. When rod withdrawal is precluded, only one loop is required to be in operation to satisfy Mode 3 accident analyses. Because the proposed change meets the Mode 3 safoty analyses, the proposed change is acceptable.

LS-24 The proposed change will add 4 notes to the CTS LCO to reflect CTS SR 4.5.3.2, LCO 3.5.4 actions, LCO 3.5.4 applicability note, and the accumulator action added in CN 9-10-M for CTS 3/4.4. This is a beyond-scope issue that is addressed in Section 3.G.9 of ths SE.

LS-26 The proposed change will relax the limit for operational leakage from PlVs. This LCO has been modified to change the allowed leakage limit for reactor coolant system (RCS) pressure isolation valves. The licensee stated that the RCS pressure isolation valve LCO permits system operation in the presence of leakage through valves in amounts which do not compromise safety. The RCS is isolated from other systems by valves.

During plant life these interfaces can produce varying amounts of reactor coolant leakage through either normal operational wear or mechanical deterioration. Increasing allowed leakage limits from 1 gpm up to 5 gpm for the pressure isolation valves will not challenge the pressure relief capacity of interfacing systems. This amount of leakage is considered nerjligible when compared with the capacity of the pressure relief valves.

Pressure isoladon valve leakage limits apply to leakage rates for individual valves. The basis for this LCO is that potential intersystem loss of coolant accidents (LOCAs) are a significant contributor to the risk of core melt. The study documented in NUREG-0677, "The Probability of Intersystem LOCA: Impact Due to Leak Testing and Operational Changes," dated May 1980, evaluated various pressure isolation valve configurations to determine the probability of intersystem LOCAs. This study concluded tnat periodic leak testing of the pressure isolation valves can substantially reduce intersystem LOCA probability. The previous criteria of 1 gpm for all valve sizes is not an indicator of imminent accelerated deterioration or potential valve failure. Leakage acceptance criteria based on valve size is consistent with the STS and, as stated above, increasing m:+_

__ leakage limits to a maximum of 5 gpm will not challenge RCS interfacing system relief

- capacity. Therefore, the proposed change is acceptable.

LS-30 The proposed change will relax the CTS SR for performing an RCS water inventory balance by allowing deferral of the balance until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation. An RCS water inventory balance cannot be meaningfully performed unless the plant is operating at steady state conditions. Therefore, CTS SR 4.4.6.2.1.d would be revised to allow deferring the RCS inventory balance in the event of a transient until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state conditions. The proposed change will provide for a mesningful test ard is, therefore, acceptable.

l LS-36 The proposed change willlimit CTS SR 4.4.4.2 to perform the 92 aay surveillance of the pressurizer PORV block valves (i.e., perform one complete cycle of each block valve) so that it is not required to be performed if the block valve is closed to meet Action a. This is a beyond-scope issue that is addressed in Section 3.G.10 of the SE.

CTS Specification 3.5 LS-4 (CN 3-02 LS-4) The proposed change revises the CTS prescriptive wording related to pump inoperability, in footnote

• to SR 4.5.3.2, to specifically addrest the emergency

)

core cooling system (ECCS) pump capability to inject into the RCS. This change involves the configuration of the centrifugal charging and safety injection pumps. The LTOP limitations on ECCS pumps, and related surveillances, are relocated to ITS 3.4.12. The requirement for having the charging pumps / safety injection pumps

' inoperable' has been revised to preclude injection into the RCS. This change is consistent with the cold overpressure analysis requirements. The intent of specifying that the required number of centrifugal charging pumps / safety injection pumps be inoperable is to preclude the possibility of injecting flow into the RCS in excess of that analyzed for the LTOP system. This change results in the operability statements being revised and allows deletion of the notes which were in place for testing or accumulator filling. Because the change does not result in a less conservativo operational position as flow to the RCS is still precluded, the proposed change is acceptable.

1 LS-4 (CN 4-01 LS-4) The proposed change will (1) revise the CTS LCO 3.5.4 Action b and SR 4.5.4.2 (the footnote) to satisfy LTOP analysis assumptions on ECCS injection sources by rendering pumps inoperable to preclude those pumps from injecting into the RCS, and (2) delete the note dealing with testing and accumulator filling. The LCO requirement to satisfy cold overpressure analysis assumptions on ECCS injection sources by rendering pumps inoperable has been revised to preclude those pumps from injecting into the RCS. Yhe change does not result in a less conservative operational position as flow to the RCS is still precluded. The intent of specifying that the required number of centrifugal charging pumps / safety injection pumps be inoperable is to preclude the possibility of injecting flow into the RCG in excess of that analyzed for the LTOP system. Because the intent of precluding the possibility of excess flow injection continues to be met by the proposed change, the proposed change is acceptable.

LS-6 The proposed change revises the CTS requirement in SR 4.5.3.1 to demonstrate ECCS train operability in Mode 4 to delete (1) the 31-day surveillance to verify the correct

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position of each valve in the ECCS flow path which is not already locked in place, and (2) the 18-month surveillance to verify automatic actuation of ECCS pumps and automatic valves. Due to the stable conditions associated with operation in Mode 4 and i

1 the reduced probability of occurrence of a DBA, the ECCS operational requirements are 1

reduced. In this mode, there is sufficient time for manual actuation of the required ECCS to mitigate the consequences of a DBA. B..:ause sufficient time exists for 3

manual actuation, the proposed charo is acceptable.

l CTS Specification 3.6 I

LS-1 The change added a statement to CTS SRs 4.6.1.1.a (footnote ") and 4.6.1.7.1 j_

(footnote +) and LCO 3.6.3 (action footnote +) on valve and blind flange surveillance l

requirements that allows verification of valves, flanges and isolation devices located in high radiation areas to be verified by use of administrative means. This adds an exception for valves, blind flanges, and der,ctivated automatic valves which are located inside containment and are locked, sealed, or otherwise secured in the closed position.

The note allows verification of valves, flanges and isolation devices located in high radiation areas to be verified by use of administrative means. These valves shall be verified closed during each cold shutdown; however, under the CTS, if an area outside of containment became a high radiation area, entry into the area would still be required to verify the closed positions. The ITS would allow verification of all areas that are high radiation areas or become high radiation areas by administrative means once they had been verified to be in the proper msition. This change is consistent with restricting access to these areas to mainte xcupational exposure as low as is reasonably achievable (ALARA), as required by 10 CFR Part 20. The probability of misalignment of these devices, once they have been initially verified in the proper position, is small j

because these valves would be under administrative control. Based on the administrative control on these valves and their location in areas where radiation exposure should be controlled, the proposed ange is acceptable.

)

LS-11 The proposed change to CTS SRs 4.6.1.7.2 and 4.6.1.7.4, for containment isolation i

valves with resilient seats, will (1) extend the leakage rate testing frequency for 18-inch pressure relief valves from once per 92 days to once per 184 day, and (2) add the requirement to perform a leakage test within 92 days of opening the valves for both sets of valves. The Icakage rate testing frequency for containment isolation valves with resilient seals is revised to the 184 days that was the minimum frequency allowed by NRC in the resolution of Multi-Plant Action (MPA) B-20," Containment Leakage Due to Seal Deterioration." A new requirernent has also been added to perform a leakage test after opening a valve because cycling the valve could introduce additional seal degradation beyond that occurring to a valve that has not been opened. This would reduce the 184-day interval in half to 92 days for the period just after the valve was opened. The interval of 92 days after opening the valve is the interval specified in the CTS for leak testing the valves and decreasing the surveillance interval (from 184 days to 92 days) is a prudent measure after a valve has been opened. Therefore, the proposed change is acceptable.

LS-19 The proposed change relaxes CTS requirements that are in a footnote to CTS SR 4.6.1.1.a and in a footnote to LCO 3.6.3. The revised footnote and a footnote added to t

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the SR state that only containment isolation valves that are not locked, sealed, or

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otherwise secured are required to be verified closed at the once per cold shutdown j

frequency. The CTS SR requires All penetrations not capable of being closed by an operable containment automatic isolation valve (and required to be closed for accident i

conditions) be verified closed on a 31-day frequency, except for valves, blind flanges, i

and deactivated automatic valves that are located inside containment and are locked i

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closed, sealed or otherwise secured in a closed position. The penetrations with valves within containment that are lockea close, sealed, or otherwise secured in a closed l

position are verified closed during each cold shutdown but not more often than once per j

92 days. Penetrations (inside or outside containment) which are isolated by manual i

valves and blind flanges that ere locked, sealed or otherwise secured are not required to

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be verified closed, since they are verified to be in the correct position prior to locking and j

securing the valve and are under administrative control. Based on the administrative l

control of containment isolation valves within containment that are locked, sealed, or j

otherwise secured, the proposed change is acceptable.

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LS-25 The proposed change will (1) delete the CTS requirement in SR 4.6.1.7.1 to blank flange and close the containment shutdow'. purge supply and exhaust (CSDPSE) isolation valves and (2) ext 6nded the frequency to once per 92 days for verification of j

these valves inside containment by adding the statement "if not completed in the l

previous 92 days." CTS 3.6.1.7 for the containment ventilation system requires the l

CSDPSE valves to be closed and blank flanged. In the event one containment isolation valve in one or more penetration flow paths is inoperable, the affected penetration flow l

path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and deactivated automatic containment l

isolation valve, a closed and deactivated power-operated containment ischtion valve, a j

closed manual valve, a blind flange, and a check valve with flow through the valve j

secured._ The requirement to close and blank flange the CSDPSE isolation valves is more conservative than needed because either closing the valve or blank flanging the valve is sufficient to have these valves be isolation barriers. Therefore, deleting the j

reference to closing and blank flanging these valves is acceptable.

]

l The CTS frequency of verifying the CSDPSE isolation valves inside containment once per 31 days is extended to 92 days in adding the statement "if not completed in 92 days" 2

to the footnote to CTS SR 4.6.1.7.1. The footnote requires the CSDPSE isolation valves and flanges located inside containment to be verified closed (or flanges installed) prior to entering Mode 4 following each cold shutdown. The extension to 92 days is considered acceptable because of the inaccessibility of the isolation devices (e.g., valve or flange) inside containment and the licensee's administrative controls that will ensure that isolation device misalignment is an urilikely possibility. This is the same time period specified in the STS actions for the similar situation of verifying penetrations with inoperable isolation valves are closed for the containment isolation devirm.:.ade containment.

Based on the above, the proposed change is acceptable.

22 -

CTS Specification 3.7 l

LS-8 The proposed change will delete the CTS SR in item 1 of Table 4.7-1 to determine gross radioactivity. The consequences of secondary system releases are limited by radiolodines and their resultant thyroid exposures, not the whole-body exposures received for the noble gases and the primary-to-secondary leakage limits and dose equivalent 1-131 limits ensure the dose analyses in the USAR remain valid. The CTS require that the gross radioactivity of the secondary system coolant be determined every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, but this surveillance is only a significant indicator of the potential offsite whole body dose. Since the radioiodines and the resulting thyroid dose are limiting, the 72-hour gross radioactivity surveillance requirement is deleted as being unnecessary.

Because the limits on primary-to-secondary leakage and dose equivalent 1-131 assure l

that the dose analyses in the USAR remain valid, the revised surveillance is more appropriate. The ITS will also require that the surveillance for verification of I-131 activity be performed every 31 days on an unconditional basis, which is more restrictive than the CTS. The proposed change will only delete gross radioactivity sampling where l

results are bounded by the primary to secondary leakage and dose equivalent 1-131 l-limits, and is, therefore, acceptable.

LS-13 The proposed change will delete the CTS SR acceptance criteria that the laboratory analyses for the CR emergency filtration / pressurization system be completed "within 31 days after removal." This requireme,it is not contained in NRC Regulatory Guide (RG) 1.52, " Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," the applicable American Nuclear Standards Institute (ANSI) standards, or the STS. The licensee stated that the failure to complete such an analysis within 31 days has insignificant safety consequences because it is very unlikely 1

that the charcoal would be degraded to the extent that there would be a complete loss of a safety function. The licensee has a ventilation filter testing program in ITS 5.5.11 that includes the testing of this ventilation system, and the laboratory testing of charcoalis in accordance with RG 1.52. Because RG 1.52 does not state that contain a requirement on completing the laboratory analyses within 31 days, the proposed change is acceptable.

LS-22 The proposed change will replace the specific CTS SR 4.7.1.3.2 to periodically verify the essential service water (ESW) system is in operation whenever the system is the supply source for the AFW pumps by a general statement to verify operability of the backup water supply. The periodicity of the verification does not change; however, the verification is relaxed to allow administrative means. Tha M ' 30uire that when the condensate storage tank (CST) contained water volume is ;... in limits that the ESW system be demonstrated operable by " verifying that the ESWS is in operation." The ITS will revise this action to " verify by administrative means" the operability of the ESW system as a backup supply to the auxiliary feedwater (AFW) pumps. The result of this change is that the ESW system would not have to be physically started should the contained water volume for the CST fall below the limit. Instead the ESWS would be required to be verified operable by administrative means. This change would include verification that the flow paths from the ESWS to the AFW pumps are operable, that the required volume of water is available, and that the pump meets its operability

- - =. _

I l requirements. This is a normal case for other specifications in the CTS. Based on this, the proposed change is acceptable.

LS-25 The proposed change will delete the requirements in CTS LCO 3.7.1.6, Actions a, for SG atmospheric relief valves being inoperable due to sealleakage. CTS LCO 3.7.1.6, Actions a and b, are revised to delete the reference to excessive seal leakage as a cause of inoperability of these valves. Sealleakage is no longer a condition of operability because the atmospheric relief valves can perform their required safety function when the valves can be opened or closed on demand and can provide controlled Mief of steam. Because sealleakage does not prevent these valve functions, seal leakage does not prevent the valves from performing their safety function. Therefore, because the sealleakage of the valves is no longer a condition for SG atmospheric relief valve inoperability, the actions in the CTS for such leakage are no longer needed and the proposed change is acceptable.

CTS Specification 3.8 LS-4 For CN 1-47 LS-4, the proposed change will revise CTS SRs required for the CTS SR 4.8.1.2 on AC sources operability in Modes 5 and 6 to include only those SRs which are applicable for operability.

For CN 2-15 LS-4, the proposed change will add a note to the CTS ER allowing certain parts of the battery SR 4.8.2.2 to not have to be performed for the DC source operability in Modes 5 and 6. The licensee stated that the note does not delete the raquirement that the battery be capable of perfc rning these functions, just that the capacity need not be demonstrated while that battery is relied on to meet the LCO.

The revisions deleted certain CTS SRs that are not applicable because they depend on ESF actuation signals (which are not required to be operational during Modes 5 and 6) and automatic load sequencing (most of these loads are not required in Modes 5 and 6).

The SRs required for AC sources operability in Modes 5 and 6 would be revised to include only those SRs which are applicable. SRs that are not applicable are those that depend on ESF actuation signals (which are not required to be operational during Modes 5 and 6) and automatic load sequencing (most of these loads are not required in Modes 5 and 6). The 10-year simultaneous auto-start of all DGs is also not applicable to Modes 5 and 6.

In addition, the note listing exceptions to SR required for Modes 5 and 6 in CTS 4.8.1.2 would be revised to include the following additional SRs: 4.8.1.1.2.a.5, 4.8.1.1.2.g.1, 4.8.1.1.2.g.2,4.8.1.1.2.g.6 through 4.8.1.1.2.g.8, and 4.8.1.1.2.g.10. SRs that are applicable but not required to be performed are those that place a DG in perallel with offsite power which increases the probability of a station blackout. The licenu stated that the change assures the performance of SRs that are necessary and safe to perform for the plant conditions. The SRs required for AC sources and DC sources operability in Modes 5 and 6 would be revisod to include only those which are applicable. In addition, notes would be added stating the SRs that are not required to ce performed for operability in the modes governed by shutdown for the AC and DC sources LCOs. SRs were not listed as applicable for shutdown because (1) the SR is only required when

j 1 )

DGs are required to be operable, (2) the SR is only required when the safety injection (SI) signal is operable, or (3) the SR is only required when the sequencers are required i

to be operable.

i For AC sources at shutdown, many of the CTS SRs involve tests that would require the l.

one required DG to be paralleled to offsite power; this condition presents a significant f

risk of a single fault resulting in a station blackout. Other tests, such as load rejection l

tests, put the availability cf the operable DG at risk during the test. To address this concem and to avoid potential conflicting TS, a note is added to not require that these surveillances be performed in Modes 5 and 6.

l For DC sources at shutdown, a note would be added stating which CTS SRs are not i

required to be performed for the DC source operability in Modes 5 and 6. Certain of the currently required SRs involve tests that would cause the battery to be rendered inoperable. If the only required operable battery were inoperable due to testing, the risk of an event occurring that would require battery operation, would present an additional risk. The exception provided by the note does not exempt the battery from the requirement to be capable of performing the particular function, only that the capability need not be demonstrated while that source of power is being relied upon to support i

meeting the LCO.

The proposed SRs would continue to provide adequate assurance of the operability of the required AC and DC source functions. The changes would delete the requirement to meet SRs that verify functions which are not required in the applicable modes of the ITS.

Based on this, the proposed changes are acceptable..

LS-12 The proposed change will add a footnote to CTS SR 4.8.1.1.2.g.7 stating that momentary transients outside the load and/or power factor rangs do not invalidate the SR tests. This is not allowed in the CTS. The licensee states that a footnote will be added stating that momentary transients outside the load range do not invalidate the test, since DG loading could change during this test due to changing bus conditions.

Some load fluctuation is expected and should not invalidate this test. The current practice of monitoring and recording load every 15 minutes during the overload part of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load test and once every hour for the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> is sufficient to ensure the DG load is within the load range. DG load found out of the load range and immediately retumed to within the band would not invalidate an DG load test. Based on this, the proposed change is acceptable.

LS-23 The proposed change will relax the CTS SR 4.8.2.1.e on battery capacity by allowing a modified performance discharge test for verifying battery capacity. This is a beyond-scope issue that is addressed in Section 3.G.4 of the SE.

l LS-26 The proposed change will restrict the operability in CTS LCO 3.8.3.2, for onsite power distribution in shutdown, to "the necessary portion of" electrical buses that are needed "to support [ equipment] required to be operable." Only the portions of these distribution subsystems necessary to supply AC and DC power to equipment required to be

i l

i.

i.

operable in shutdown must be operable. The change revises the requirement for operable onsite shutdown power. The CTS requires that one train (subsystem) of the various power supplies and buses be operable. The change requires that only the necessary portions of these subsystems be operable. The necessary portions are those portions required to support the equipment in that train which is required to be operable in the existing shutdown conditions. There is no reason to have portions of the power i

systems operable ti:at are not supporting components which are being credited in the safety ar'alyses for shutdown events. Because the necessary portions of the power j

systems will remain operable to provide power to equipment required to be operable, the proposed changs is acceptable.

4 CTS Specification 3.9 l

LS-2 The proposed change will delete CTS SR 4.9.1.1 to verify reactivity conditions in the i

LCO for Mode 6 prior to (1) removing or unbolting the reactor vessel head, and (2) 1 withdrawal of any control rod greater than 3 feet from its fully inserted position. The first of these requirements is redundant to the requirerrient imposed by the applicability note i

in ITS LCO 3.9.1 to meet the LCO prior to entering Mode 6 from Mode 5. Compliance i

with the LCO is assured by verifying boron concentration in accordance with ITS SR l'

3.9.1.1. In this case, unbolting the vessel head in preparation for removal is part of the j

definition of Mode 6. Therefore, this requirement is redandant to the requirement to verify boron concentration prior to entry into Mode 6. The second requirement that involves withdrawal of control rods is redundant because the analysis used to determine the boron concentration limit specified in the COLR considers the most adverse conditions of fuel assembly and control rod position. The boron concentration is sufficient to maintein k,n s 0.95 with the most reactive rod control cluster assembly completely removed from its fuel assembly. Because these requirements are redundant to the requirements in ITS SR 3.9.1.1 and the COLR, the proposed change is acceptable.

LS-3 The proposed change, for the source range flux monitor in CTS SRs 4.9.2.b and 4.9.2.c and a new SR, will replace the analog COT requirements by a channel calibration in Mode 6. The analog COT is within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to core alterations and once per 7 days; the channel calibration would be every 18 months. In Mode 6, the source range monitors are required for indication only and there are no precise setpoints associated with these instruments. In this capacity, the source range instrumentation is typically used to read a relative change in count rate and is monitored for significant changes in count rate which are important to evaluate the change in core status, in the STS, indicating instruments only require channel checks and channel calibrations. The more frequent ACOTs are applied only to those channels with operational interlocks or other setpoint actuations. Therefore, the Mode 6 channel checks and channel calibration requirements every 18 months for the source range monitors are adequate to assure their operability, considering the more frequent ACOTs performed on this instrumentation in other Modes, the effectiveness of these surveihnce requirements in maintaining other indicating. instruments operable, and the accuracy required of these instruments in Mods 6. Therefore, the proposed change is acceptable.

1 ye..,, my, 4

.% p,..

a

. _. = _

_ ~ _. _. _. _. _ _ _

_ LS-4 The proposed change will delete CTS SR 4.9.4 to perform verification of containment

- building penetration status within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of core alteration or movement of irradiated fuel. The purpose of the CTS SR is to ensure the operability of the containment penetrations that must be closed or capable of closing to prevent the release of radioactivity in the event of a fuel handling accident (FHA). The SR is intended to assure that mitigation features are available and has no impact on the

. probability of an accident occurring. The applicability statement for this LCO is "During CORE ALTERATIONS or movement of irradiated fuel within the containment." The requirement to verify the LCO is met within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of starting the evolutions for which the LCO is applicable is redundant because the LCO must be met at the time that the evolutions occur. Therefore, the proposed change is acceptable.

. LS-6 The proposed change will relax CTS requirements in LCO 3.9.8.1 by allowing the removal of the RHR loop from operation for additional purposes other than the performance of core alterations in the vicinity of the hot legs. The equivalent requirement in ITS LCO 3.9.5 contains a note allowing the removal of the RHR loop from operation provided no activities are permitted that would reduce the RCS boron concentration. This will allow increased flexibility for core mapping and isolation valve testing which are needed to be done. Therefore, the proposed change is acceptable.

LS-7 The proposed change will delete CTS LCO 3.9.9 Action a to close each purge valve when the containment ventilation system is inoperable. The function of the purge valves is to close following a FHA to prevent the escape of radioactivity from containment.

Because the containmcnt ventilation TS requirements would be interated irna ITS 3.9.4 on containment penetrations during refueling ope ations, this has the effect of chang! g the actions required when t' ventilation system.. anoperable from closing the purge valves to suspending core a s. rations and irradiated fusi n.1 ament (i.e., place the plant in a mode outside, the L r". s he applicability of the LCO and required actions for both CTS 3.9.9 and IT S 3.9.-

is identical i e during core alterations or movement of irradiated fuel assemblies within containment. Therefore, neither of these LCOs would oe in effect if cos e alterations or movement of irradiated fuel were suspended. Beca e L

changing Ue action from (1) requiring the valves to be closed to prevent a radioactivity release to (2) suspending activities which could lead to a FHA (and to a radioactivity release) would have the saue effect in mitigating the consequences of the accident, the proposed change is acceptable.

LS-9 The proposed change will delete the "within 31 days after removal" requirement in CTS SRs 4.9.13.b.2 and 4.9.13.c for completion of laboratory analyses for the emergency exhaust system (EES) carbon sample. To assure charcoal adsorber operability, the CTS SR requires that a laboratory analysis be performed and the results obtained within 31 days of removing the charcoal sample. The sample must be sent to an offsite laboratory for this analysis. This requirement is intended to avoid extended plant operation with degraded charcoal filters. This requirement is not contained la the ITS nor is it contained in RG 1.52 or the applicable ANSI standards. There is no safety significant basis for maintaining this time limit as a CTS requirement. Laboratory analyses are performed under contract with a laboratory on a prompt basis, and it is not necessary to prescribe a time limit within CTS for completing the analysis. Failure to complete an analysis within 31 days has insignificant safety consequences because it is 9

^*

w_

c.

-e

e j very unlikely that the charcoal would be degraded to the extent that there would be a j

complete loss of a safety function. The licensee has a ventilation filter testing program in ITS 5.5.11 that includes the testing of this ventilation system, and the laboratory j

testing of charcoal is in accordance with RG 1.52. Because RG 1.52 does not state that 1

contain a requirement on completing the laboratory analyses within 31 days, the proposed change is acceptable.

LS-21 The proposed change will delete the CTS LCO 3.9.2 requirement related to indication provided by the source range detectors for refueling operations instrumentation. The change would eliminate requirements associated with indication channels that are not required to mitigate boron dilution events. The requirements for visual indication for plants that do not rely on a boron dilution analysis would be discussed in the ITS Bases and the requirements for audible indication would be eliminated. In Mode 6, the source range monitors are required for indication only and there are no precise setpoints associated with these instruments. The source range instrumentation is monitored for significant changes in count rate which is important to evaluate the change in core status. The accepted convention for defining criticality does not require precise or specific setpoints or indication, but only requires verification of a slowly increasing count rate. The ITS requirements consist of maintaining two source range neutron flux

, monitors operable to ensure that redundant monitoring capability is available to detect changen W core reactivity. There is no requirement for an audible signal or alarm to initiab operator response because in Mode 6 reactivity changes would be slow and a borr,n dilution accident is not postulated. The occurrence of a boron dilution event is pre :luded by maintain'ng the isolation valves from unborated water sources secured in the closed position in a ccordance with ITS 3.9.2. During refueling, the source range molitors are designed to prcvide visual and audible indication of neutron count rate to M operators. The proposed deletion of requirements for audible indication for these ils would not affect the availability of visual indication. There are no alarms,

) setpoints associated with these channels that are required to be interk~ks 4.4 operable 1.. ig Mode 6. In additic~

4.

iode 6 the source range instruments provide no automatic si. aation function used F 1.

sation of accidents. Because the proposed change only eliminates requiremerr, that are not needed to mitigate boron dilution events, the proposed change is acc e table.

LS-22 The proposed change will delete the CTS SR 4.9. 4.1 requirement to verify water level 4

within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the start of movement of fuel assemblies. CTS LCO 3.9.9.1 requirements on the required water level are applicable at the time that movement of

- fuel assemblies is performed. The SR for level verification within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to irradiated fuel movement is not needed because the SR for verifying reactor vessel level every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is retained in ITS SR 3.9.7.1 and is sufficient for ensuring that the water level over the core is at an acceptable level. Because of ITS SR 3.9.7.1 requirement on verifying refueling water level every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the proposed change is acceptable.

LS-26 The proposed change will add a new action to CTS LCO 3.9.13 for degradation of the fuel building pressure envelope. The change provides specific required actions for failed surveillances designed to detect ventilation system envelope degradation. These surveillances require a positive or negative pressure limit be satisfied in the area with i

the associated required ventilation train operating. While other surveillances in the

. ~

. same specification test the operability of the ventilation train, these surveillances ensure the envelope leak tightness is adequate to meet the design assumptions. However, there are no corresponding CTS action associated with these surveillances. The new action was modeled after the STS on restoring a building ventilation pressure boundary.

The new action would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the capability to maintain the proper pressure by allowing for routine repairs before requiring the unit to perform an orderly shutdown. Because the proposed action time for restoring the building ventilation pressure boundary is the same as the time to restore a similar ventilation pressuta boundary in the STS, the proposed change is acceptable.

CTS Section 6.0 LSe2 The proposed change will extend the time to complete the analysis of the fuel oil from 30 days to 31 days in CTS 6.8.4.g.b. The licensee stated that the surveillance interval for verifying that other properties are within limits for ASTM 2D fuel oil will be changed from "within 30 days" to "within 31 days" after obtaining a sample. The fuel properties that can have an immediate detrimental impact on diesel combustion, (i.e., API gravity, kinematic viscosity, flash point and appearance) are verified prior to addition to the storage tank. The "other properties" may be analyzed after addition to the tank. The licensee stated that the 31-day verification interval for these properties is acceptaole because the fuel properties of interest, even if they are not within their stated limits, would not have an immediate effect on diesel generator operation. The CTS 30-day verification interval was probably chosen because it was a convenient time interval for sending the sample and receiving the results from the laboratory selected for te sting and NUREG-1431 has selected a 31-day testing interval. The 1-day increase it the interval would not have a significant effect on the acceptability of the diesel fuel oil and, therefore, the proposed change is acceptable.

For the reasons presented above, these less restrictive requirements are acceptable because they will not affect the safe operation of the station. The TS requirements that remain are consistent with current licensing practices, operating experience, and station accident and transient analyses, and provide reasonable assurance that public health and safety will be protected.

D. Relocated CTS Details (Not Entire Specifications)

When requirements in the TS have been shown to give little or no safety benefit, their removal from the TS may be appropriate. This includes details that do not support the safety analyses for the plant and, therefore, are not necessary for inclusion in the TS. This section discusses the relocation of details within the CTS to licensee-controlled documents. The relocation of entire specifications from the CTS to licensee-controlled documents is discussed in Section 3.E below. In most cases, relaxations previously granted to licensees on a plant-specific basis were the result of (1) generic NRC actions, (2) new staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups comments on the STS (i.e., the TSTF process). The NRC staff reviewed generic relaxations contained in the STS and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. The WCGS design was also reviewed to

$ determine if the specific design be.,is and licensing basis of the WCGS were consistent with the technical basis for the model requirenients in the STS, and thus provide a basis for the proposed ITS. A significant number of changes to the CTS involved the removal of specific requirements and detailed information from individual specifications evaluated to be Types 1

~ through 5 that follow:

Type 1 Details of System Design Type 2 Descriptions of System Operation Type 3 Procedural Details for Meeting TS Requirements i

l Type 4 Requirements Redundant to Regulations Type 5 Requirements Not Supporting the Safety Analyses The following discussions address why each of the above types of information or specific requirements are not required to be included in ITS.

Details of Svstem Der' q (Type 1)

'The design of the facility is required to be described in the USAR by 10 CFF. 50.34. In addition, the quality assurance (OA) requirements of Apper. dix 3 % 10 CFR Part 50 require that station design be documented in controlled procedures and drawings, and maintained in accordance with an NRC approved QA plan (Chapter 17 of the USAR). In 10 CFR 50.59 controls are specified for changing the facility as described in the USAR, and in 10 CFR 50.54(a) criteria are specified for changing the OA plan. The ITS Bases also contain descriptions of system design and ITS 5.5.10 specifies 10 CFR 50.59 controls for changing the Bases. Removing descriptive details of system design from the CTS !s acceptable because this information will be adequately controlled in the USAR, controlled design documents and drawings, or the TS Bases, as appropriate.

Cycle-specific design limits are moved from the CTS to the core operating limits report (COLR) in accordance with NRC GL 8816. ITS 5.6.5 has the programmatic requirements for the COLR.

Descriotions of System Ooeration (Type 2)

The plans for the normal and emergency operation of the facility are required to be described in the USAR by 10 CFR 50.34. Controls specified in 10 CFR CO.59 apply to changes in procedures as described in the USAR. Controls yt.

Sd in 10 CFR 50.54(a) apply to changes to the QA Program. The ITS Baso* als< contain descriptions of system operation and ITS 5.5.10 specifies that 10 CFR St.. Iwil. be used for making changes to the Bases. It is acceptable to remove details of system operation from the TS because this type of information will be adequately controlled in the USAR, OA program, station operating procedures described in the USAR, and the ITS Bases, as appropriate.

.~.

30-Procedural Details for Meetina TS Reauirements (Type 3)

Details for performing action and surveillance requirements are more appropriately specified in the USAR, station procedures required by ITS 5.4.1, the ITS Bases, the technical requirements manual (TRM), or in programmatic documents, such as the offsite dose calculation manual (ODCM), which are required by ITS 5.5. Typically, details for performing action and surveillance requirements are already contained in the station procedures required by ITS 5.4.1. ITS 5.4.1.a requires written procedures to be established, implemented, and maintained for station operating procedures including procedures recommended in NRC RG 1.33, Revision 2, Appendix A, February 1978.

These procedures ensure proper implementation of action and surveillance requirements. For example, control of the station conditions appropriate to perform a i

surveillance test is an issue for procedures and scheduling and has previously been determined to be unnecessary as a TS restriction. As indicated in GL 91-04, " Changes i

in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel i

Cycle," allowing this procedural control is consistent with the vast majority of other SRs i

that do not dictate station conditions for surveillances. Prescriptive procedural information in an action requirement is unlikely to contain all procedural considerations necessary for the station operators to complete the actions required, and referral to j

station procedures is, therefore, required in any event.

Removing procedural details for meeting TS requirements from the TS is acceptable because locating such details in the USAR, the ITS Basea, the TRM, or in programmatic documents required by ITS Section 5.5, as appropriate, will maintain an effective level of regulatory control while providing for a more appropriate change control process, such as 10 CFR 50.59 and ITS 5.5.14, " Technical Specifications Bases Control Program."

Similarly, deleting reporting requirements in the CTS is appropriate because ITS Section 5.6, " Reporting Requirements," 10 CFR 50.36 and 10 CFR 50.73 adequately cover the reports deemed to be necessary.

Reauirements Redundant to Reaulations (Type 4)

Certain CTS administrative requirements are redundant to regulations and thus are i

relocated to the USAR or other appropriate licensee-controlled documents. The Final Policy Statement allows licensees to relocate to licensee-controlled documents CTS requirements that do not meet any of the criteria for mandatory inclusion in the TS.

Changes to the facility or to procedures as described in the USAR are made in accordance with 10 CFR 50.59. Changes made in accordance with the provisions of other licensee-controlled documents are subject to the specific requirernents of those documents. For example,10 CFR 50.54(a) governs changes to the QA plan, and ITS 5.5.1 governs changes to the ODCM and ITS 5.5.14 governs changes to the ITS Bases. Therefore, relocation of the administrative details identified above, is acceptable.

Reauirements Not Sucoortino the Safety Analyses (Type 5)

The TS rule,10 CFR 50.36, provides criteria for determining what requirements should be specified in the TS LCOs. These criteria are based on meeting the safety analyses T

=ame- +

i for the plant. In some cases; while a TS LCO may support the safety analyses, certain j

other requirements within the specification, such as a SR, may not. Since the Commission's Final Policy Statement allows licensees to relocate CTS LCOs that do not meet any of the 10 CFR 50.36 criteria to licensee-controlled documents, it is also acceptable to allow licensees to also relocate certain requirements within LCOs, to licensee-controlled documents, when these requirements do not support the safety analyses for the plant.

I 3

i Table LG lists the requirements and detailed information in the CTS that are being relocated to j

licensee-controlled documents and not retained in the ITS. Organized by CTS section, the table provides the following: (1) the CN, (2) the CTS reference where the detail was located; (3) a summary description of the relocated details; (4) the document to contain the relocated 4

details or requirements (i.e., the new location); (5) the regulation or ITS section for controlling future changes to the relocated detail or requirement (i.e., the control process); (6) a characterization of the change; and (7) a reference to the specific change type, as discussed I

i above, for not including the information or specific requirements in the ITS (i.e., Type 1,2,3,4, or 5).

l The NRC staff has concluded that these types of detailed information and specific requirements do not need to be included in the ITS to ensure the effectiveness of ITS to adequately protect i

the health and safety of the public. Accordingly, these requirements may be moved to one of the following licensee-controlled documents for which changes are adequately governed 'y a j

regulatory or TS requirement:

TS Bases controlled in accordance with ITS 5.5.14, " Technical Specifications Bases Control Program."

Documents that have controls established by the Administrative Controls section i

of the ITS (e.g., ODCM in ITS 5.5.1, inservice inspection program in ITS 5.5.8, explosive gas and storage tank radioactivity monitoring program in ITS 5.5.12,

)

diesel fuel oil testing program in ITS 5.5.13, and core operating limits report in ITS 5.6.5).

USAR (which includes the TRM by reference) controlled by 10 CFR 50.59.

OA plan, as approved by the NRC and located in Chapter 17 of the USAR, 2

controlled by 10 CFR Part 50, Appendix B, and 10 CFR 50.54(a).

The above is not a complete list of the acceptable licensee-controlled documents that could be 1

used to incorporate relocated CTS requirements. Table LG of details relocated from CTS, Table R of relocated CTS requirements, and Table LS of less restrictive change to CTS (where a few LS changes included relocations of CTS requireme: t::) list the licensee-controlled i

documents for the relocated CTS requirements.

To the extent that requirements and information have'oeen relocated to licensee-controlled documents, such information and requirements are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.

i -

Further, where such information and requirements are contained in LCOs and associated requirements in the CTS, the NRC staff has concluded that they do not fall within any of the j

four criteria contained in 10 CFR 50.36 and discussed in the Final Policy Statement (see b

n-

32 -

l Section 2.0 of this SE). Accordingly, existing detailed information and specific requirements, such as generally described above, may be removed from the CTS and not included in the ITS.

E.

Relocated Entire CTS Specifications The' Commission's Final Policy Statement states that LCOs and associated requirements that do not satisfy or fall within any of the four specified criteria (now contained in 10 CFR 50.36) may be relocated from the CTS (an NRC-controlled document) to appropriate licensee-controlled documents. This section of the SE discusses the relocation of entire specifications in the CTS to licensee-controlied documents. These specifications include the LCOs, action statements (i.s., LCO actions), and associated SRs. In its application and its supplements, the licensee proposed relocating such specifications from the CTS to the USAR (which includes the TRM by reference). The staff finds that relocation of these requirements to the TRM is acceptable, in that changes to the TRM will be adequately controlled by 10 CFR 50.59. These provisions will continue to be implemented by appropriate station procedures (i.e., operating procedures, maintenance procedures, surveillance and testing procedures, and work control procedures).

- The licensee, in electing to implement the specifications of the STS, also proposed, in accordance with the criteria in the Final Policy Statement and 10 CFR 50.36, to entirely remove certain specifications from the CTS and place them in licensee-controlled documents. Table R lists all specifications that are being relocated from the CTS to licensee-controlled documents.

Table R is organized by each R-type DOC to the CTS, in a manner consistent with the organization of requirements in the CTS. Table R has the following: (1) the CN, (2) a references to the relocated CTS requirements,-(2) summary descriptions of the relocated CTS requirements, (3) name of the document that will contain the relocated requirements (i.e., the new location); and (4) the method for controlling future changes to the relocated requirements (i.e., the control process).

The NRC staff's evaluation of each relocated specification listed in Table R is provided below, in order of the CTS section and then the CN number.

1.

CN 1-38 R CTS Table 3.3-1, Functions 6.a and Action 5, Source Range Neutron Flux, Reactor Trip and Indication, Shutdown (CTS 3/4.3)

There are requirements for the source range neutron flux, reactor trip and indication in shutdown specified in CTS Table 3.3-1. In Modes 3,4, and 5, when all control rods are fully inserted and the rod control system is incapable of rod withdrawal, the source range neutron flux function does not provide input to any reactor trip function nor is it credited for mitigation of any DBA. At one time, the source range neutron flux signal was credited in the analysis of the inadvertent boron dilution event; however, as described in previous license amendment 96 for WCGS, this analysis was revised to take credit for other alarms and not the source range neutron flux function. Based on this and because the source range neutron flux function in these conditions does not satisfy any of the four criteria of 10 CFR 50.3S(c)(2)(ii), it is being relocated from the TS to the USAR. The operation of this function will continue to be maintained through plant procedures as it does provide important alternate indication to the reactor operators. The USAR is an acceptable licensee-controlled document for this 4

em

- =*~-* p amv e w;& *~

_s,

_ __ _ _ _. _ _ _ _. _ _. _ _. _ _ _ information becuse changes to the USAR are controlled by 10 CFR 50.59. This relocation is acceptable.

- 2.

CN 3-01-R CTS 3/4.9.3, Reactor Decay Time (CTS 3/4.9) -

The requirements in CTS 3/4.9.3 on the decay time that the reactor core must be subcritical before there is movement of irradiated fuel in the reactor core are being relocated to the TRM.

This LCO requires the reactor to be subcritical for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> to allow the radioactive decay of l

the short-lived fission products. The screening criteria for including the requirements in the ITS have been satisfied for Criterion 2 since decay time is consistent with the assumptions used in an accident analysis; however, the activities necessary to be performed at WCGS before commencing movement of irradiated fuel ensure that 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of subcriticality will elapse -

before there is movement of irradiated fuel in the core. Therefore, because the CTS is not required to assure that 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> have elapsed prior to fuel movement, the decay time LCO and SRs in the CTS may be relocated to the TRM, a licensee-controlled document outside TS.

The TRM is included by reference in the USAR and is an acceptable licensee-controlled document; therefore, the relocation is acceptable.

The two relocated specifications from the CTS discussed above are not required to be in the ITS because they do not fall within the criteria for mandatory inclusion in the TS in 10 CFR 50.36(c)(2)(ii). They are not needed to obviate the possibility that an abnormal situation or event will give rise to an immediate threat to the public health and safety, in addition, the NRC staff finds that sufficient regulatory controls exist under 10 CFR 50.59 to maintain the effect of the provisions in these specifications. The NRC staff has concluded that appropriate controls have been established for all of the current specifications that are being moved to the USAR.

The relocations are the subject of a iicense condition discussed in Section 6.0 of this SE. Until incorporated in these licensee-controlled documents, changes to these specifications, j

information, and requirements will be controlled in accordance with the current applicable procedures that control these documents. Following implementation of the ITS and incorporation of these relocated requirements, the NRC will audit the removed provisions to i

ensure that an appropriate level of control has been achieved.

F.

Control of Specifications, Requiremer.ts, and Information Relocated from the CTS in the ITS conyarsion, the licensee will be relocating specifications, requirements, and detailed information from the CTS to licensee-controlled documents outside the CTS. This is discussed in Sections 3.D and 3.E above. The facility and procedures described in the USAR (which includes the TRM by reference), can only be revised, including deletions, in accordance with the provisions of 10 CFR 50.59, which ensures records are maintained and establishes appropriate control over requirements removed from the CTS and over future changes or deletions to the reo Jirements.' Other licensee-controlled documents contain provisions for making changes consistent with other applicable regulatory or TS requirements; for example, the ODCM can be changed in accordance with ITS 5.5.1; the emergency plan implementing procedures (EPIPs) can be changed in accordance with 10 CFR 50.54(q); and the administrative instructions that implement the CA plan can be changed in accordance with 10 CFR 50.54(a) and 10 CFR Part 50, Appendix B. Temporary procedure changes are also controlled by 10 CFR 50.54(a). The

1 34-documentation of these changes will be maintained by the licensee in accordance with the

. record retention requirements specified in the licensee's OA plan for WCGS and such applicable regulations as 10 CFR 50.59.

The license condition for the relocation of requirements from the CTS, discussed in Section 6.0 of this SE, will address the implementation of the ITS conversion, and when the relocation of the CTS requirements into licensee-controlled documents will be completed. The relocations to the USAR and TRM may be included in the next required update of the USAR in accordance with 10 CFR 50.71(e).

G. Eva!uation of Other TS Changes included in the Application for Conversion to ITS

- This section addresses the beyond-scope issues (BSis) in which the licensee proposed changes to both the CTS and STS. The staff listed the BSis in the two notices of consideration that it published in the Federal Register on February 26,1999 (64 FR 9546) and on March 1 (64 FR 10028).

The changes discussed below are listed in the order of the applicable ITS specification or section, as appropriate (from CTS Section 3.3 to CTS Section 6.0).

1. ITS 3.4.5 CTS 3.4.1.2. Establishes Temperature Restrictions on Startina an Idle Reactor Coolant Pumo (RCP) When Below the LTOP Armina Temoerature of 368

. dearees F. (CN 1-05-M for CTS 3/4.4)

~ A note is proposed to be added to CTS LCO 3.4.1.2 and ITS 3.4.5 to establish temperature restrictions that must be met before starting an idle reactor coolant pump when below the LTOP system arming temperature of 368'F. The proposed change is not in the STS.

CTS LCO 3.4.1.2 is applicable in Mode 3. The LTOP arming temperature of 368'F is in Mode 3. The note being added to CTS LCO 3.4.1.2 would prevent starting a reactor coolant pump with the RCS cold leg temperature less than or equal to 368'F (LTOP arming temperature), unless the secondary side water temperature in the steam generator is less than or equal to 50'F above the cold leg RCS temperature. This is an assumption in the WCGS LTOP analysis that prevents a low temperature overpressure event due to a thermal transient when a reactor coolant pump is started. Adding this note constitutes an additional restriction not found in the CTS or ITS. The staff finds this note acceptable in that it provides additional control to help ensure the assumption in the LTOP analysis remains valid.

Similar notes are included in CTS LCO's 3.4.1.3 and 3.4.1.4.1 (ITS 3.4.6 and 3.4.7). These notes state that a reactor coolant pump shall not be started unless the secondary side water temperature in the steam generator is less than or equal to 50*F above the cold leg RCS temperature. The notes currently do not identify that the restriction on starting a reactor coolant pump is applicable only when RCS cold leg temperature is less than or equal to 368'F. This restriction is added to these notes. Because the proposed note is consistent with the WCGS LTOP analysis, the proposed change is acceptable.

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( 2. ITS SRs 3.4.5.2 and 3.4.6.2:

CTS SRs 4.4.1.2.2 and 4.4.1.3.2. Reolace Steam

. and LCO 3.4.7 Generator Secondarv Side Water Level (SGSDWL) of

" wide rance... areater than or soual to 10%" with " narrow rance.. areater than or eoual to 6%." LCO 3.4.1.4.b.

Reolace SGSSWL Of "10% of the wide rance" with "66%

of the wide ranoe." (CN 1-15-M for CTS 3/4.4)

CTS SR's 4.4.1.2.2 and 4.4.1.3.2 require steam generator (SG) levels to be periodically verified to be greater than or equal to 10% wide range water level. The proposal is to change this level-l value to 6% narrow range water level. The proposed change is not in tra STS.

The CTS value of 10% wide range does not ensure all SG tubes are covered. The licensee l

stated that the proposed 6% level value includes uncertainties, and corresponds to a SG level approximately 100 inches above the top of the highest SG tube. This level is sufficient to ensure the tubes remain covered and that the SGs provide an adequate heat sink for removal for decay heat. Additionally the proposed value of 6% narrow range level is used in the Wolf Creek emergency operating procedures. Because the proposed SG level value of 6% narrow range will ensure SG tubes are ' maintained covered to provide an adequate heat sink for decay heat removal, the proposed change is acceptable.

A similar change is proposed for CTS LCO 3.4.1.4.b. This LCO currently requires that in Mode 5, with the reactor coolant loops filled and one RHR loop operable and in service, the secondary side water level of at least two SGs be maintained " greater than 10%'of the wide range." The proposed change is not in the STS.

This CTS level value of 10% wide range does not ensure all SG tubes are maintained covered with water. The proposal is to increase this value to " greater than 66% of the wide range." The licensee stated that, for Mode 5 conditions, the 66% wide range level corresponds to the top of the highest SG tube, with margins added for instrument loop errors and readability. The wide range instrumentation is calibrated for cold conditions. Because this value will ensure SG tubes remain covered in Mode 5 when SGs are required to be operable, the proposed change is acceptable.

3. ITS 3.7.16 No CTS Soecification. Soent Fuel Storaae Pool Boron Concentration.

(CN 14-09-M for CTS 3/4.7)

The proposed change would add Specification 3.7.16 to the CTS on the boron concentration in the spent fuel storage pool. The new specification is based on STS 3.7.17; however, the proposed minimum acceptable boron concentration for the spent fuel storage pool would be different from the acceptable values given in the CTS. The STS do not provide a value for the minimum boron concentration. Therefore, the proposed minimum boron concentration of 2165 ppm is different from the CTS and the STS.

l The licensee stated that a criticality analysis was performed for its proposed reracking of the spent fuel storage pool to determine the minimum boron concentration limit for the new specification. The reracking of the poolis being done to increase the spent fuel assemby

)

l density in the pool. The reracking is addressed in the licensee's letters of March 20, May 28, l

J 36 -

June 30, August 28, September 4, November 20, and December 8,1998 and is being evaluated by the staff as a separate issue, which is not part of this conversion.

)

The criticality analysis was performed assuming that all rack cells are fully loaded with fresh fuel i

assemblies, each with a minimum of 16 integral fuel burnable adsorber (IFBA) rods. The minimum boron concentration will maintain keff in the pool less than or equal to the regulatory limit of 0.95 for spent fuel pools. This is for a fully loaded pool and accounts for the possibility of misloaded fuel assemblies. The reference fuel assembly has the maximum enrichment 5.0 l

. weight % U-235. Manufacturing uncertainities that were used in the original analyses for the j

pool were used in this analysis. Based on this analysis, the licensee stated that the minimum i.

concentration of 2165 ppm boron will maintain keff less than or equal to 0.945, which is more conservative than the 0.95 value that is acceptable to the staff. The value of 2165 ppm boron i

was proposed for the minimum boron concentration for the pool.

l Because the minimum boron concentration will maintain keff at an acceptable value below 1.0 l

with acceptable assumptions and conservatisms, the proposed change is acceptable.

i j

4. ITS SR 3,8.4.7 '

CTS SR 4.8.2.1.e. Allow Substitution of a Modified Performance i

ITS SR 3.8.4.8 Discharae Test for the Batt<N Service Test. (CN 2-25-LS-23 for CTS 3/4.8)

The proposed change would relax CTS SR 4.8.2.1.e on battery capacity by allowing a modified performance discharge test for verifying battery capacity. The proposed change would also allow that the performance discharge test may be performed in place of the battery service test of CTS SR 4.8.2.1.d to only allow-the " modified" performance test to replace the service test.

The change would retaln the restriction that the discharge test could replace the service test l

only once per 60 months. The proposed change is not in the CTS or the STS.

l The change would allow the performance of a modified performance dischargo test in lieu of a i

service test at any time. CTS SR 4.8.3.1e allows the performance of a modified performance i

discharge test in lieu of a service test only once per 60 months. IEEE-450-1995, Section 5.4 places no such limitation on use of a discharge test in lieu of a service test since the discharge rate is required to envelope the duty cycle of the service test. A modified performance j

discharge test is a test of the battery's ability to provide a high-rate, short-duration load. This l

will often confirm the battery meets the critical period of the load duty cycle, in addition to j

determining its percentage of rated capacity. Initial conditions for the modified performance l

discharge test should be identical to those specified for a modified performance test. IEEE-i 450-1995, Section 5.4 states that, "A modified performance discharge test can be used in lieu j

of a service test at any time."

l This proposed change would provide additional flexibility in allowing the performance of a modified performance discharge test in lieu of a service test at any time and the change is i

consistent with IEEE-450-1995. The proposed Bases for ITS SR 3.8.4.7 adequately describes the modified performance discharge test. Based on this, the proposed change is acceptable.

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i 5. ITS SR 3.8.4.8 CTS SR 4.8.2.1.e. Revise Batterv Caoacity Surveillance Test

- Acceotance Criteria. (CN 2 27-M for CTS 3/4.8)

CTS SR 4.8.2.1.e requires periodic comp!etion of a battery performance discharge test. The performance test detects changes in battery capacity over time and trends overall battery degradation due to age and usage. The acceptance criteria in CTS 4.8.2.1.e for a performance discharge test is "80% of the manufacturer's rating." The proposed change is to revise this acceptance criteria to "85% of the manufacturer's rating" in corresponding ITS SR 3.8.4.8.

1 The proposed change is not in the CTS or the STS.

j The licensee proposed this change to reflect a recent design modification made by Wolf Creek that replaced the Gould manufactured square cell batteries with AT&T manufactureo round cell batteries. The AT&T round cell battery performance characteristics differ from the square cell batteries that were replaced.

- To address the difference in performance characteristics, the licensee proposed that the CTS i

SR 4.8.2.1.e acceptance criteria be revised to "85% of the manufacturer's rating." This acceptance criteria is based on consideration of the following: industry standards (IEEE 450 and IEEE 485), manufacturer's recommendations, margin in the plant specific Wolf Creek design, degradation mechanisms associated with round cells, industry experience with round cells, extensive manufacturer testing, other CTS surveillance test requirements, and the original procurement acceptance criteria. The licensee's detailed response providing this information is in its response to Question (O) 3.8.4-17 in its letter of March 6,1999, (ET 99-0010). The licensee has also committed to evaluate any adverse trends identified during the performance discharge tests in accordance with its corrective action program. The ITS Bases willinclude the method for determining battery capacity and the corrective action evaluation of any adverse trends during the tests.

. The staff considers the proposed acceptance criteria, including the licensee's commitment to evaluate adverse trends, is acceptable based on current industry standards. Based on this, the proposed change is acceptable.

l

6. ITS SR 3.8.4.1 CTS SR 4.8.2.1.a.2. Decrease Minimum Batterv Terminal Voltaae. and ITS Table 3.8.6-1 CTS Table 4.8-2. Increase Minimum Float Voltaoes.

(CN 2 20 A for CTS 3/4.8)

The proposed change would increase the minimum battery cell float voltages for DC sources in CTS Table 4.8-2 by 0.01 to 0.02 volts. A corresponding change would be made to decrease the total required battery terminal voltage for a DC subsystem from 130.2 to 128.4 volts on float charge. The proposed changes are not in the STS.

Verifying the battery cell float voltages and total terminal voltage while on float charge helps to ensure the effectiveness of the charging system and the ability of the batteries to parform their intended safety function. These proposed changes in minimum cell float voltage and

. corresponding total required battery voltage would reflect a recent design modification made by 4

i the licensee that replaced the Gould manufactured square cell batteries with AT&T manufactured round cell batteries. These proposed values are in accordance with IEEE-450, m-

4 1995 edition and the manufacturer's recommendations for float voltage. The proposed voltage values are based on the nominal design voltage of the batteries and are consistent with the

' initial voltages assumed in the battery sizing calculations. Therefore, the proposed changes are acceptable.

The following additional BSis were not evaluated in the draft SE issued to the licensee on i

February 2,1999.

- 7. ITS Table 3.3-1 Table 3.3-1. Action 3 and New Action 3.1. Function #5 and Conditions F and G Egginote h to ITS Acolicable Modes. (CN 1-07-LS-3 for CTS 3/4.3)

The proposed changes would (1) extend the completion time for CTS Action 3.b from no time specified to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for channel restoration or changing the power level to either below P-6 or above P-10, (2) change the applicability of the intermediate range neutron flux channels and delete CTS Action 3.a because it is now outside the revised intermediate range neutron flux channel applicability, and (3) add a less restrictive new action that requires immediate 2

suspension of operations involving positive reactivity additions and a power reduction below P-6 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but no longer requires a reduction to Mode 3.

With one intermediate range neutron fiux channel inoperable, CTS Action 3.a applies below the P-6 interlock. For those times that the plant is above P-6 but below 10% RTP (the P-10 interlock setpoint), CTS Action 3.b applies. Action 3.b would be revised to establish a 24-hour completion time for channel restoration or changing the power level to either below P-6 or above P-10. The intermediate range neutron flux channels provide protection between these power levels and the applicable modes have been revised accordingly. The source range neutron flux detectors provide protection below P-6 and the power range neutron flux detectors provide protection above P-10. The addition of the 24-hour completion time (the CTS has no

. specified completion time) limits the window of operation during which the intermediate range neutron flux trip function provides protection in a 1-of-1 logic configuration. Additionally a power increase is an allowed ITS option end the action would ensure protection by exiting the range of the intermediate range neutron flux channel and entering the range of the four power range neutron flux channels. This change is acceptable because of the low probability of occurrence 4

of a reactivity transient during the time period that would require an intermediate range flux trip.

With both intermediate range neutron flux channels inoperable in Mode 1 (below P-10) and

- Mode 2 (above P-6), LCO 3.0.3 would be entered under the current TS and the plant would have to be in Mode 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. With both intermediate channels inoperable, new Action 3.1 requires immediate suspension of operations involving positive reactivity additions and a power reduction below P-6 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The new Action 3.1 is less restrictive since a reduction to Mode 3 would no longer be required; however, the CTS are overly conservative in this area. In Mode 2 below P-6, the source range channels are required to be operable to provide protection against positive reactivity excursions; therefore, the required action for both intermediate range channels inoperable should be to exit plant conditions where the intermediate neutron flux trip function is needed to provide protection. There is a low probability of occurrence of an event during the 2-hour completion time that may require the protection afforded by the intermediate range neutron flux trip. These actions actually provide a more 4

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I timely and appropriate redress to the condition than entering LCO 3.0.3; therefore, the proposed change is acceptable.

8.' ITS SR 3.3.1.8 CTS Table 4.3-1. Functions #2.b and #5. and New Notes 19 and 20.

Quarterly COTS Have Been Added to CTS Table 4.3-1 for the Power

^

- Ranae Neutron Flux-low. Intermediate Ranae Neutron Flux. and Source Banae Flux Trio Functions. (CN 122-M for CTS 3/4.3) i The licensee proposed to add quarterly COTS to CTS Table 4.3-1 for the power range neutron j

flux-low, intermediate range neutron flux, and source range flux trip functions. The CTS only require a COT prior to startup for these functions. A new Note 17 is proposed to be added to require that the new quarterly COT be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reducing power below P-10 for the power range and intermediate range instrumentation (P-10 is the dividing point marking the applicability for these trip functions), if not performed within the previous 92 days.

In addition, the licensee proposed to revise Note 9 such that the P-6 and P-10 interlocks are verified to be in their required state during all COTS on the power range neutron fiux-low and intermediate range neutron flux trip functions. The frequencies for performing the COTS on power range and intermediate range channels are not consistent with the STS.

A review of plant history (including performance and verification) has revealed that COTS on the power range and intermediate range instrumentation require one to two hours per channel to perform. This is consistent with the COT time allowance in the STS for source range instrumentation, as 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is provided for the 2-channel system. However, the power range and intermediate range instrumentation consist of 6 channels and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> would not be sufficient time to perform these COTS in a quality manner. The licensee has proposed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to perform the power range (2-channels) and intermediate range (4-channels) COTS to have sufficient time to perform the COTS in a quality manner. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is consistent with the j

time allowed for the source range COT. Based on this, the proposed change is acceptable because the 12-hour time period allows sufficient time to conduct the COTS..

9. ITS LCO 3.4.12 CTS 3.4.9.3. Notes. Add Four Notes to Reflect Other LCOs. Actions. And Notes SBm (CN 9-17-LS 24 for CTS 3/4.4) l The proposed change would add 4 notes to CTS LCO 3.4.9.3 to reflect CTS SR 4.5.3.2, 4.

1 LCO 3.5.4 Actions a and b, LCO 3.5.4 applicability note, and the accumulator action added in the change CN 9-10-M for CTS 3/4.4. Note 1 on centrifugal charging pump (CCP) swap operations is a relaxation of the CTS because it allows both CCPs to be capable of injecting into the RCS for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> throughout low temperature overpressure protection (LTOP) applicability.

Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The initia1 conditions and assumptions for the LTOP mass addition and heat injection transients will be unchanged.

Actions will be taken to insure that only one CCP is capable of injecting into the RCS during the LTOP applicability. CTS 3.5.4 provides 4-hour AOTs if one SI pump and two CCPs are capable i

of injecting during the most critical portion of the LTOP applicability (lowest RCS temperature and the plant may be water solid). The 4-hour AOT for one Si pump is deleted. The 1-hour AOT for two CCPs capable of injecting during Mode 4 minimizes the actual time that more than

i' i. one CCP is capable of injection. One' hour will provide sufficient time to complete the CCP

~

swap and asociated administrative requirements. The proposed change will not affect the probability of any event initiators nor will the proposed change affect the ability of any safety-i related equipment to perform its intended function. There 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 j

4 is acceptable.

i

10. ITS SR 3.4.11.1 CTS SR 4.4.4.2. Limit When to Perform the 92-Day Surveillance of the l

Pressurizer PORV Block Valves And State Action d Does Not Anolv if the i

Block Valve is inocerable to Satisfy Actions b or c. (CN 4-9-LS-36 for l

CTS 3/4.4)

The proposed change would limit the CTS requirement to perform the 92-day surveillance of i

the pressurizer PORV block valves so that it is nM required to be performed if the block valve is closed to meet Action a. A note will also be aoded to LCO Action d to state that the action does not apply if the block valve is inoperable solely to satisfy LCO Actions b or c. The proposed change is not in the CTS or the STS.

1 The proposed change will limit CTS SR 4.4.4.2 to perform the 92-day surveillance of the pressurizer PORV block valves (i.e.', perform one complete cycle of each block valve) so that it is not required to be performed if the block valve is closed to meet Action a. Credit is taken only for the manual operation of the PORVs during the SGTR accident; however, the capability j

.to manually cycle the PORVs will be unaffected by the proposed change. This change will not j

affect the ability of the block valve to open, if closed to meet Action a, in the mitigation of an SGTR.~ Deferral of the block valve cycling surveillance will not diminish the design capability of the block valve to open against differential pressures that would be present after an SGTR because the block valves are capable of opening against 2485 psig, the safety valve lift i

pressure, and pressurizer pressure decreases after an SGTR. The lack of quarterly block valve cycling, which could extend to a complete cycle since Action a allows continued operation with i-the block valves closed, does not decrease the likelihood of successful pressurizer relief since power remains available to the block valve motor operator (s) and the surveillance frequency for j

the PORVs can be as long as 18 months. The exclusion proposed for Action d has no effect on i

the accident analysis because the PORVs are already assumed to be unavailable. Because the block valves remain capable to open in the mitigation of a SGTR and the surveillance frequency remains with an acceptable 18-month limit, the proposed change is acceptable.

1 l

11. ITS LCO 3.7.10 CTS LCO 3.7.6. New Action c. and LCO 3.7.7. New Action c.

Condition D (CN 10-20-LS-39 for CTS 3/4.7) j 1

The proposed change would add a CTS action for ventilation system pressure envelope degradation that allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the CR pressure envelope through repairs before requiring the unit to perform an orderly shutdown. The new action has a longer AOT than LCO l

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3.0.4 which the CTS would require to be entered immediately.

4 4

This change provides specific required actions for failed surveillances designed to detect

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ventilation system' pressure envelope degradation. These surveillances require a positive or i

negative pressure limit be satisfied in the area with the associated required ventilation train i

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-- operanc.g. While other surveillances in the same specification test the operability of the ventilation train, these surveillances ensure the pressure envelope leak tightness is adequate to meet the design assumptions. However, there are no corresponding conditions, required actions, or completion times associated with these surveillances. Under the CTS, TS 3.0.3 must be entered and in the case of the fuel building with the pressure limits not met, TS 3.0.3 would not be an appropriate action. The new action was modeled after the STS on restoring a building ventilation pressure boundary. The new action would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the capability to maintain the proper pressure by allct'ng for routine repairs before requiring the unit to perform an orderly shutdown. Because the proposed action time for restoring the building ventilation pressure boundary is the same as the time to restore a similar ventilation pressure boundary in the STS, the proposed change is acceptable.

12. ITS SR 3.8.2.1 CTS LCO 3.8.1.2.c. Action. SR 4.8.1.2. Add Operabilitv. Action and Surveillance Reauirements for One Load Shedder and Emeraency Load Seouencer in Modes 5 and 6. (CN 1-70-M for CTS 3/4.8)

The proposed change would add operability, action, and surveillance requirements on the shutdown portion of one load shedder and emergency load sequencer (LSELS) in Modes 5 and

6. These requirements are not in the CTS or the STS.

In CTS Table 4.3-2, the modes for which the LSELS actuation logic test is applicable are Modes 1 to 4. This test is being moved to ITS SR 3.8.1.21 because the LCO for this surveillance is also applicable for Modes 1 to 4. The surveillance requirements from LCO 3.8.1 that are applicable in the shutdown modes are listed in SR 3.8.2.1. In Modes 5 and 6, portions of the LSELS are maintained operable to support a potentialloss of offsite power (LOOP). The proposed change incorporates the shutdown requirements by adding (1) requirements on the shutdown portion of LSELS operability, (2) corresponding action statements to respond to LSELS inoperability, and (3) an actuation logic test for surveillance on the LSELS. The proposed changes are current practice for maintaining the LSELS during shutdown and are, therefore, acceptable.

13. ITS 5.2.2.d CTS 6.2.2.e. Reauirements Concernina Overtime Would Be Reolaced by a Reference to Administrative Procedures for the Control of Workina Hours, (CN 1-09-A for CTS 6.0)

The proposed change is to replace the CTS 6.2.2.e requirements concerning overtime being in accordance with the NRC Policy Statement by a reference to the licensee's administrative procedures that control working hours. This is a change to the CTS and the STS.

The licensee stated that the proposed change provides reasonable assurance that safe plant operations will not be jeopardized by impaired performance caused by plant staff working excessive hours. There are specific controls on plant staff working hours in procedures that require a deliberate decision-making process for determining the working hours to minimize the potential for impaired personnel performance, and that there are also procedures to control changes to these procedures.

The staff concludes that the proposed replacement of CTS 6.2.2.e by a reference to administrative controls does not change the requirements associated with working hours, and,

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-i - therefore, is an administrative change.' Based on the requirements in CTS 6.2.2.e not being changed and there being controls on any changes to the procedures governing allowed working hours, the proposed change is acceptable.

14. ITS 5.2.2.f CTS 6.2.2.a. Eliminate the Title of Shift Technical Advisor. (CN 1-15-A for CTS 6.0)

-The proposed change would eliminate the title of " shift technical advisor" (STA). The engineering expertise would be maintained on shift, but not as a separate individual, in accordance with the Commission Policy Statement on the STA function. This is a change to the CTS and the STS.

The licensee stated that the STA are not used at all plants and is not used at WCGS. The function will be fulfilled by one of the other on-shift plant staff. The CTS section is proposed to be revised so that it does not imply that the STA and the shift supervisor must be different individuals. Option 1 of the Commission's Policy Statement on engineering expertise on shift is satisfied by assigning an individual with specified education qualifications to each operating shift as one of the senior reactor operators required by 10 CFR 50.54(m)(2)(i) to provide the

- technical expertise on shift. Therefore, the STS function will be fulfilled by one of the other on-shift plant staff that has qualification specified in the Commission's Policy Statement on engineering expertise.

The staff concludes that the proposed elimination of the STA will not eliminate the requirement for the technical expertise on shift represented by the STA. The proposed change does not alter the requirement for the technical expertise on shift, and, therefore, is an administrative change.= The licensee will be maintaining the technical expertise represented by the STA on shift although not through an individual called an STA. This meets the Commission's Policy Statement on engineering expertise on shift and, therefore, the proposed change is acceptable.

15. ITS 5.5.4.1 CTS 6.8.4.e.7. Dose Rate Limits in Radioactive Effluent Controls Procram for Releases to Areas Bevond the Site Boundarv Would Be Revised to Reflect 10 CFR Part 20. (CN 2-18 A for CTS 6.0)

The proposed change would revise the dose rate limits in the radiological effluent controls program (RECP) to reflect the current requirements in 10 CFR Part 20. This is a change to the CTS and the STS.

i The RECP is addressed in and controlled by ITS 5.5.4. The licensee stated that the changes to the CTS section maintain the same overall level of effluent control while retaining the operational flexibility that exists in the CTS. The licensee stated that the addition of the regulatory requirements in the ITS is intended to eliminate confusion or improper implementation of the new 10 CFR Part 20 requirements. The licensee has added the specific dose limits (1) for noble gases and (2) for lodine-131, lodine-133, tritium, and all radionuclides in particulate form with half lives greater than 8 days.

The staff concludes that the proposed change is to incorporate in the CTS the current requirements in 10 CFR Part 20, and, as such, is an administrative change. Because the licensee is incorporating requirements that are in the regulations, the change is acceptable.

4 43 -

16. ITS 5.5.4.k CTS 6.8.3.e. Clarification Statements Added to Radioactive Effluents 4

Controls Proaram. (CN 2-22-A for CTS 6.0) l

. The proposed change will revise the RECP in ITS 5.5.4 to add clarifiying statements denoting that the provisions of CTS 4.0.2 and 4.0.3, which allow extensions to surveillance frequencies, are applicable to these activities. This is a change to the CTS and the STS.

The added statements of applicability clarify the allowances for surveillance frequency extensions and for performing missed surveillances in CTS 4.0.2 and 4.0.3 with respect to the RECP activities. Generic Letter (GL) 89-01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications [RETS) and the Relocation of Details of RETS to the Offsite Dose Calculational Manual or Process Control Program," allowed licensees to relocate RETS and establish RECP in the administrative section of their TS. Because the proposed change effectively implements the the CTS requirements that were relocated in

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accordance with GL 89-01, the proposed change is acceptable.

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17. 'ITS 5.7.1 CTS 6.12.1. Revised to Meet Current Reauirements in 10 CFR Part 20 i

and Guidance in NRC RG 8.38. Hiah Radiation Areas Access Controls.

(CN 3-11 A for ITS 6.0)

' The proposed changes would revise CTS 6.12.1 to provide high radiation area access control alternatives pursuant to 10 CFR 20.203(c)(2) and to meet the current requirements in 10 CFR Part 20, on such access controls. This is a change to the CTS and the STS.

CTS 6.12.1 and 6.12.2 provide high radiation area access controls that are alternatives pursuant to the regulations in 10 CFR 20.203(c)(2). The CTS section would be revised to meet the current requirements in 10 CFR Part 20. The other plant requirements will remain the same. The licensee has proposed to make the following changes: (1) replace the reference to 20.203(c)(2) by 20.1601, (2) state 1000 mR/h is at 30 cm (12 in.), and (3) add that the high

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radiation area is greater than 100 mrem /hr. Because the change follows the regulations, the l

proposed change is acceptable.

18. ITS 5.6.4 CTS 6.9.1.5. Delete Reauirement to Reoort Challenaes to Pressurizer PORVs or Safetv Valves. (CN 3-18-LS-5 for CTS 6.0)

The licensee proposed to delete tne CTS 6.9.1.5 requirement to provide documentation of all challenges to the RCS PORVs or safety valves. The proposed reduced requirement is not in the STS.

The reporting of pressurizer safety and relief valve failures and challenges is based on the guidance in NUREG-0694,"TMI-Related Requirements for New Operating Licenses." The guidance of NUREG-0694 states the following: " Assure that any failure of a PORV or safety

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valve to close will be reported to the NRC promptly. All challenges to the PORVs or safety valves should be documented in the annual report." NRC Generic Letter 97-02, " Revised Contents of the Monthly Operating Report" requests submittal of less information in the monthly operating report. The generic letter identifies what needs to be reported to support the NRC j

Performance Indicator Program, and availability and capacity statistics. The generic letter does

. not specifically identify the need to report challenges to the pressurizer safety and relief valves.

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44 The NRC indicated that this information was not needed for its pedormance indicator program and, therefore, would not need to be reported.

p Based on this, the proposed change to delete the requirement to provide documentation of all challenges to the pressurizer power operated relief valves or pressurizer safety valves is acceptable.

4 4

5.0 -

COMMITMENTS RELIED Uf_QN in reviewing the proposed ITS conversion for the WCGS, the staff has relied upon the licensee commitment to relocate certain requirements from the CTS to licensee-controlled documents as described in Table LG of Details Relocated from Current Technical Specifications, Table R of Relocated Current Technical Specifications, and Table LS of Less Restrictive Changes to Current Technical Specifications attached to this SE. The licensee has submitted a license condition to make this commitment enforceable. Such a commitment from the licensee is important to the ITS conversion because the acceptability of removing certain requirements i

. froni the TS is based on those requirements being relocated to licensee-controlled documents i

where further changes to the requirements will be controlled by the regulations (e.g., changes to the USAR will be in accordance with 10 CFR 50.59) or the ITS (e.g., changes to the ITS Bases are in accordance with ITS 5.5.14).

i 6.0 LICENSE CONDITIONS

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There are scheduling problems with the first performance of the SRs in the ITS that will be new

- or revised compared to the SRs in the CTS. The licensee proposed the following license condition to define the schedule to begin performing the new and revised SRs during or after the implementation of the ITS:

i For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

I For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the 3

date the surveillance was last performed prior to the implementation of this amendment.

For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last j

surveillance performed prior to the implementation of this amendment.

The staff has reviewed the above schedule for the licensee to begin performing the new and revised SRs and concludes that it is an acceptable schedule. The allowance for the i

surveillance interval in ITS 3.0.2 also applies to the surveillance intervals specified in the above j

license condition.

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45-i in its comments on the draft SE in its letter of March 5,1999, the licensee provided the follow'.ng examples on how a new or revised ITS SR would meet the above SR license conditions, to clarify the meaning of the license conditions.

If an SR is new (i.e., it did not exist in the CTS), the first license condition above applies.

If this new SR has a frequency of 31 days, the license condition requires that the SR be performed within 38 days (31 days plus the allowed SR 3.0.2 extension) following the implementation date of the license amendment.

If an SR had a frequency of 92 days in the CTS and has a frequency of 31 days in the ITS, the second license condition above applies. The license condition requires that the SR be performed within 115 days (92 days plus the SR 3.0.2 extension) after the date last performed prior to the implementation date of the license amendment. The next performance of the SR must be within the next 38 days (31 days plus the SR 3.0.2 extension).

If an SR had a frequency of 7 days in the CTS and has a frequency of 31 days in the ITS, the fourth license condition above applies. The license condition requires that the SR be performed within 38 days (31 days plus the SR 3.0.2 extension) after the date last performed prior to the implementation date of the license amendment.

if an SR has acceptance criteria in the ITS that differ from the acceptance criteria in the CTS and the frequency for the SR is 31 days and has not changed, the third license condition above applies. The license condition requires that the SR be first performed using the new acceptance criteria within 38 days (31 days plus the SR 3.0.2 extension) following the date last performed prior to the implementation date of the license amendment.

If an SR has acceptance criteria in the ITS that differs from the acceptance criteria in

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the CTS and the SR had a frequency of 92 days in the CTS and has a frequency of 31 days in the ITS, the second and third license conditions above apply. The license conditions require that the SR be first performed using the new acceptance criteria within 115 days (92 days plus the SR 3.0.2 extension) after the date last performed prior to the implementation date of the license amendment. The next performance of the SR must be within the next 38 days (31 days plus the SR 3.0.2 extension).

If an SR has acceptance criteria in the ITS that differs from the acceptance criteria in the CTS and the SR had a frequency of 7 days in the CTS and has a Neauency of 31 days in the ITS, the third and fourth license conditions above apply. The ficcase conditions require that the SR be first performed using the new acceptance critena within 38 days (31 days plus the SR 3.0.2 extension) after the date last pedoned prior to the implementation date of the license amendment.

The examples show that a revised or new ITS SR may come under more than one of the above SR license conditions. The staff has reviewod the above examples and concludes that the licensee's interpretation of the SR license conditions is acceptable.

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7.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Kansas State official was notified of the proposed issuance of the ITS conversion amendment for the WCGS. The state offical had no comments.

8.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.21,51.32, and 51.35, an environmental assessment and finding of no significant impact was published in the Federa/ Registeron March 30,1999 (64 FR 15186), for the proposed conversion from the CTS to the ITS for the WCGS. Accordingly, based upon the environmental assessment, the Commission has determined that issuance of this amendment will not have a significant effect on the quality of the human environment.

9.0 CONCLUSION

The NRC staff approves the licensee's changes to the WCGS CTS with modifications documented in the revised submittals. For the reasons stated infra in this SE, the NRC staff finds that the ITS issued with this license amendment comply with Section 182a of the Atomic Energy Act,10 CFR 50.36, and the guidance in the Final Policy Statement, and that they are in accord with the common defense and security and provide adequate protection of the health and safety of the public.

The WCGS ITS provides clearer, mc u readily understandable requirements to ensure safer operation of the station. The NRC staff concludes that the ITS satisfy the guidance in the Commission's Final Policy Statement, on technical specification improvements for nuclear power reactors, with regard to the content of TS, and conform to the STS provided in NUREG-1431 with appropriata modifications for plant-specific considerations. The NRC staff further concludes that the ITS satisfy Section 182a of the Atomic Energy Act,10 CFR 50.36, and other applicable standards. On this basis, the NRC staff concludes that the proposed ITS for the WCGS are acceptable.

The staff has also reviewed the beyond-scope changes to the CTS as described in this SE. On the basis of the evaluations described herein for each of the changes, the NRC staff also concludes that these changes are acceptable.

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security, or to the health and safety of the public.

Attachments:

1. Table A of Administrative Changes to Current Technical Specifications

2. Table M of More Restrictive Changes to Current Technical Specifications

3. Table LS of Less Restrictive Change to Current Technical Specifications

4. Table LG of Details Relocated from Current Technical Specifications

5. Table R of Relocated Current Technical Specifications

l I Principal Contributors:

N. Gilles C. Shiraki R. Tjader C. Schulten T.Liu R. Giardina J. Luehman E.Tomlinson T.Le A.Chu j

M.Weston M.Reardon J.Donohew Date: March 31,1999 5

.