ML20211F363

Retracts LERs 96-005-00 & 96-005-01 Which Were Submitted Re Violation of TS 3.9.4, Containment Bldg Penetration. Further Review of Event Has Disclosed That Loop Seals Were Sufficient to Prevent Direct Access

ML20211F363
Person / Time
Site:	Wolf Creek
Issue date:	09/24/1997
From:	Warren C WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
WO-97-0091, WO-97-91, NUDOCS 9710010029
Download: ML20211F363 (2)

Text

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Clay C. Warren WQLF CREEK NUCLEAR OPERATING CORPORATION Chief Opmating Officer September 24, 1997

'O 97-0091 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C, 20555

Subject:

Docket No. 50-482: Retractior of Licensee Event Report 96-005-00 and Supplement 96-005-01 Gentlemen WCNOC is retracting Licensee Event Report (LER) 96-005-00 and its supplement 96-005-01. The LER was submitted as a violation of Technical Specification 3.9.4, ' Containment Building Penetration. "

j Further re'<iew of the event has dinclosed that the i.op seals were sufficient to prevent direct access from

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the containment atmosphere to the outside atmosph re. The attached evaluation provides the basis for the retraction.

If you shoult' have any questions regarding this subnittal, please contact me at (316) 364-8831 extension 4485, or Mr. Richard D. F3.annigan at extension 4500.

f very truly yours, 9710010029 970924 /

PDR ADOCK 05000482 PDR V /)

S Clay C. Warren

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CCW/jad i

7ttachmetat wt W. D. Johnson (NRC), w/a h.

E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a 50010.:

P O. Box 411 i Burhngton. KS 66839 / Ptv ae. (316) 364 8831 An Equa! Cpportundy Empe . . r HCVET n.

, Atf.achment to WO 97-0091 e -C 'page 1 of 1 on' March 14, 1996, at 0310 hours0.00359 days <br />0.0861 hours <br />5.125661e-4 weeks <br />1.17955e-4 months <br />, while performing SYS BM-201, " Steam Generator Draining," Operators directed the opening of containment isolation

. valve BM-V046 to allow draining of the B and C Steam Generators. Core alterations were in progress at this time. Technical Specitication 3.9.4 requires that each penetration prosiding direct access from the containment atmosphere to the outside atmosphere shall be either closed by an isolation valve, blind flange, or manual valve, or approved functional equivalent, or be capable of being closed by an OPERABLE automatic containment purge isolation valve. Technical Specification 3.9.4 is applicable during core alterations or movement cf irradiated fuel within the containment. The water drained from Steam Generators B and C was non-radioactive, secondary system water. Valve BM-V046 wcs open for one hour and twenty-four minutes. During that time, the flow of water varied and toward the end of the event went down to a trickle.

Due to the piping configuretion and atmospheric conditions in both buildings, a loop seal was formed during the draining process and no direct air to air access occurred.

l The most limiting. credible accident during core alterations, and-the basis for Technical Specification 3.9.4, is a fuel handling &ccident. Under this scenario,=the Containment is net considered to pressurize. With no potential for containment pressurization, a loop seal prevents direct access. WCNOC has issued a new procedure, AP 21D-004, " Control of Containment Penetrations During shutdown operations,' which explicitly states a loop seal is adequve for meeting Technical Specification 3.9.4. This procedure also describes wnen Containment Closure, as defined in Generic Letter 88-17, is required. In the latter case, containment penetration closure devices are required to remain intact throughout a postulated loss of shutdown cooling accident. A loop seal is not acceptable when Containment closure is required.

The event descriptions - of LER 96-005-00 and its supplement 96-005-01 were factually correct. however, because direct access did not occur, the incident should not . have been reported as a violation of Technical Specifications.

Based on the-above discussion, WCNOC is retracting LER 96-005-00 and its supplement 96-005-01.

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