ML20215H411
| ML20215H411 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/19/1987 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20215H413 | List: |
| References | |
| ET-87-0222, ET-87-222, NUDOCS 8706240095 | |
| Download: ML20215H411 (10) | |
Text
W@ NUCLEAR OPERATING LF CREEK John A. Bailey i
Vk;e President i
Engineering and Technical Services June 19, 1937 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C. 20555 Letter: ET 87-0222 Re:
Docket No. 50-482 Subj:
Revision to Technical Specification 3/4.3.3 - Radiation Monitoring for Plant Operation Gentlemen:
The purpose of this letter is to transmit an application for amendment to Facility Operating License No.
NPF-42 for Wolf Creek Generating Station
- Station, Unit No.
1.
This license amendment proposes revising Technical Specification 3/4.3.1, which addresses Radiation Monitoring for Plant Operation.
This application for amendment revises Wolf Creek Generating Station, Unit No.
1, Technical Specification 3/4.3.3, Radiation Monitoring for Plant Operation.
The proposed revision changes the required numer of minimum channels OPERABLE for Table 3.3-6 Functional Unit 1.a.,
Containment Gaseous Radioactivity High (GT-RE 31 & 32).
The requested Atmosphere revision also modifies ACTIONS 27 and 30 of Table 3.3-6 to permit an extended allowed outage time.
A complete Safety Evaluation and Significant Hazards Consideration are provided as Attachments I and II respectively.
The proposed changes to the Technical Specification is provided in Attachment III.
In accordance with 10 CFR 50.91, a copy of this application, with attachments is being provided to the designated Kansas state official.
Enclosed is a check (No. 000181) for the $150.00 application fee required by 10 CFR 170.21.
hh D
P P.O. Box 411/ Burlington, KS 66839 / Phone: (316) 364-8831 gO An Equal opportunity Ernployer M/Ft4C/ VET gdC O/d// FAN l
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r-ET 87-0222 Pege 2 June 19, 1987 The proposed revision to the Wolf Creek Generating Station Technical Specifications will be fully inplemented within 30 days of formal Nuclear Regulatory Commission approva'.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.
Very truly yours, 1
John A. Bailey Vice-President JAB:jad Engineering and Technical Services Enclosure Attachments:
I - Safety Evaluation II - Significant Hazards Consideration III - Proposed Technical Specification Change cc:
P0'Connor (2)
RMartin JCummins GAllen i
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i STATE OF KANSAS
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SS COUNTY OF COFFEY
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John A. Bailey, of lawful age, being first duly sworn upon oath says that he
. is - Vice-President Engineering and Technical Services of Wolf Creek Nuclear
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Operating Corporation; that he has read the foregoing document and knows the i
content thereof; that he has executed that same for and on behalf of said Corporation with full power and authority to do so; and that 'the facts therein stated' are true and correct to the best o f-his knowledge, information and belief.
I By-I John A. Bailey- (
Vice-President Engineering ani.
Technical Services i
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i j,UBS,C,QBR$ and sworn to before me this b day of
,.1987.
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.This amendment request revises Wolf Creek Gen' rating Station kWCGS),
'Urdt; e
No.-
- 1, -
Technical Specification 3/4.3.3, FadiationMonitoringfprPlant(
. Operation to decrease the required ainimum channels operable from tW to one '
for the Containment Atmopshere-Ge. nous. Radioactivity-High radiatien renitors j
)
(GT RE-31 and 32) and increasc the allowed outage ' time for the Fuel BM1 ding Exhaust-Gaseous Radioac tivity-High (GG RE-27 and 28) mobitors and the Air.
Intake-Gaseous Radioactivity-High (GK RE-04 and 05) monitor.
Back round 3
4 fL L
Technical. Specification 3/4.3.3 currently requixesUtha t >the Conta(cN C:
j Purge Isolation Valves be closed, whenever.GT RE-31 or 32 is not 0PER2LE. k This is overly restrictive, because other monitors M.so' provide d'autor.ap;te-signal to isolate' Containment Pu*ge on high 'pontainment radiatifn lwels.
When CONTAINMENT. INTEGRITY is required, pressure inside the @ d ainment'
. ill slowly. build up, mainly due to numerous air-operdtef valves.
Building w
The. purge valves are used. to periodically bleed pressure down' to,
approximately. atmospheric conditions.
During; routine operation with no gir:
leaks in Containment, the purge valves are uied to bleed-pressur,e down t
approximately once a week.:
However,; when air leaks develop, the. time interval between purges decreases substantially.- During a.134 day periot of continious power operation at WCGS the inter 4 between purges had decreased
.to less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
The restriction of maintaining. the. purge v a1Lves d
f closed whenever one of these monitors is out of service could resu?.t in Containment pressure exceeding Technical Specification limits before the.
I I^
monitor is able to be placed back in service and' the purge valves reopened.
s During COLD SHUTDOWN when the Coctainment equipment hatch is open,.the Containment Shutdown Purge System is in' operation.
This' system provides a filter ed and monitored release path for air from the Containment Building.
A considerable amcunt of maintenance is.normally performed in the.
Containment Building. during COLD SHUTDOWN.
This increased work activity causes the high efficiency filters on 'these monitors to periodically. clog.
Until the filter is replaced, the affected monitor is inoperable..'and the Containment purge valves must. be closed.
Air leaving the. Containment Building, when the-purgo valves are closed, will be unfiltered and not directly monitored.
If the purge valves were left open, air leaving the Containment Building would remain filtered (charcoal and HEPA filvers) And j
monitored by other OPERABLE radiation monitors.
't Technical Specification Table 3 3-6 ACTIONS 27 and 30 presently stata. 9 hat' i
neither the Control Room or the Fuel Building radiation monitors can be out of service for more than one hour, without placing the appropriate ventilation system into its safeguards mode.
Anytime either of.the systems i
is placed in its safeguards mode, a pressure gradient is created across the i
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Attachment I to ET 87-0222 Page 2 of 4 June 19, 1987 doors to these areas.
This results in two areas of concern; a personnel hazard to ~ people who have to open and pass through these doors, and added wear-and tear on these doors which may cause premature failure.
Addicionally, unnecessary running of the ventilation systems, may cause premature wear.
Increasing the time that these radiation monitors can be
_ i_
.out of service, will allow radiation monitor repair or service t-o be completed and have the monitors placed back in service without unnecessarily
?
starting emergency ventilation equipment.
' Evaluation GT RE-3L and 32 serve two major functions. The first function is to provide a Contaihment Purge Isolation Signal (CPIS) and a Control Room Ventilation Isolatior; Signal, (CEVIS) on increasing containment radiation levels.
The CPIS is also actuated by the Containment Purge System Noble Gas ' Activity Monitors GT RE-22 and 33 and from a Containment Isolation Signal.
All four of these radiation monitors, 31, 32, 22, and 33, essentially sample the same air.
The second function of GT RE-31 and 32 is to aid the detection of RCS leakage.
Technical Dpecifications require only one of these monitors to be
' OPERABLE to fulfill this function.
The purpose of a Containment Purge Isolation is to protect the public from a radioactive release and to contain high airborne activity within the Containment Buildin6;
Uhen the Reactor Coolant System is pressurized, the only plausible uncontrolled method of rapidly increasing containment airborne radiation levela.to the point of an isolation, is by a substantial
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Loss of Coolant Accident (LOCA).
Small coolant leaks will only cause a
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gradual increase in containment activity, which is easily noticed by the i-C Control Room Operators.
It is expected that the operators would evaluate i
the situation 'and would terminate Containment Purge if it was in operation.
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During a substantial LOCA, the' Pressurizer Pressure will decrease rapidly and cause a Reactor Trip Signal and a Safety Injection Signal.
This Safety Injection Signal will also cause a Containment Isolation Signal which l
isolates Containment Purge.
When the plant is shutdown and depressurized, the only plausible uncontrolled means of rapidly raising airborne activity in Containment is by a
-fuel handling accident.
During any fuel movement activities in Containment, fuel hat:dling personnel are in constant communication with the l
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Control Room and would immediately notify them of any problems.
Attachmtnt I to ET 87-0222
.Page 3 of 4 June 19, 1987 Table 3.3-6 of Wolf Creek's Technical Specifications requires both Containment Atmosphere Gaseous Radioactivity monitors, GT RE-31 and 32 to be OPERABLE in all MODES.
The action statement for when one of these monitors is out of service is, " operation may continue provided the containment purge valves are maintained closed." The Bases for this Technical Specification states that " sufficient redundancy is maintained to permit a channel to be out-of-service for testing or maintenance." Sufficient redundancy exists to warrant the proposed reduction in the required minimum channels OPERABLE for Functional Unit 1.a..
Lengthing the time allowed outage time to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for radiation monitors GK i
RE-04 or 05 and for GG RE-27 or 28, is appropriate. GK RE-04 and 05 provide an isolation signal to the Control Room Emergency Ventilation System, when i
incoming outside air increases to a specified radiation level.
Either monitor will send an isolation signal to both safety trains of the Control Room Emergency Ventilation System.
Technical Specification 3.7.6, which concerns the Control Room Emergency Ventilation System, allows one of its two safety trains to be out of service for seven days.
Technical Specifications presently require that, if either GK RE-04 or 05 becomes inoperable for more than one hour, the Control Room is isolated from the outside air by placing the Control Room Emergency Ventilation Sysem in service.
If the ventilation system is left in its normal line-up after taking one radiaton monitor out of service, the redundant radiation monitor remains OPERABLE and capable of supplying an isolation signal should radiation levels in the incoming air increase to the specified setpoint.
GG RE-27 and 28 present a similar situation.
These monitors provide a Fuel Building Isolation Signal to the Fuel Building Ventilation System and start the Emergency Exhaust System.
The Emergency Exhaust System creates a small negative pressure in the Fuel Building, by directing all exhausting air through two sets of redundant HEPA and charcoal filters.
Technical Specifications presently require that the Emergency Exhaust System be started and the normal ventilation system secured if one of these two redundant radiation monitors becomes inoperable for more than one hour.
During normal operation, one safety train of the Emergency Exhaust System may be out of service for up to seven days.
Only during fuel movement must both be in service.
During fuel movement health physics personnel are present with portable radiation monitors.
If the Fuel Building Ventilation System is left in its normal line-up after either GG RE-27 or 28 becomes inoperable, the remaining OPERABLE redundant radiation monitor will be available to provide the required Fuel Building Isolation Signal when radiation levels in the Fuel Building increase to a specified setpoint.
The proposed changes will not affect probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety-analysis report.
In all three proposed changes, when a radiation monitor is allowed to be taken out of service, redundant OPERABLE radiation monitors are still in service.
The monitors that remain in service, provide the same signal to the same equipment and at the same setpoint as the monitor that is removed from service.
Attochmeat I to ET 87-0222 Page 4 of 4 June 19, 1987 The proposed change would not create the possibility for an accident or malfunction of a different type than any previously evaluated in the safety -
analysis report.
This proposed change does not involve changing any setpoints or involve changing how existing equipment is operated.
These changes reduce the burden on the control room staff, by allowing sufficient time for monitor repair without unnecessarily actuating the emergency ventilation systems.
The proposed changes will not affect the margin of safety as defined in the i
basis for ar.y technical specification.
The proposed changes do not alter i
the manner in which safety limits and limiting safety system setpoints are i
determined.
Redundant monitors remain OPERABLE during the extended allowed outage time and under the revised minimum OPERABLE channels requirements.
Conclusion Based on the above discussions and the considerations presented in Attachment II, the proposed revisions to Technical Specifications 3/4.3.3 does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to sa fety previously evaluated in the safety analysis report; or create a. possibility for an j
accident or malfunction of a different type than any evaluated previously in the safety analysis report; or reduce the margin of safety as defined in the basis for any technical specification. Therefore, the proposed revisions do not adversely affect or endanger the health or safety of the general public or involve a s4;nificant safety hazard, i
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8 ATTACHMENT II SIGNIFICANT HAZARDS EVALUATION
SIGNIFICANT HAZARDS CONSIDERATION This amendment request revises Wolf Creek Generating Station (WCGS),
Unit No.
1, Technical Specification 3/4.3.3, Radiation Monitoring for Plant Operation.
The proposed revision reduces the required number of minimum channels operable from two to one for Table 3.3-6 Functional Unit 1.a.,
Containment Atmosphere-Gaseous Radioactivity High (GT-RE 31 & 32).
The 4
requested revision also modifies ACTIONS 27 and 30 of Table 3 3-6 to permit 1
an allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with the number of OPERABLE channels one less than the minimum channels OPERABLE requirement.
1.
The proposed amendment does not involve a significant increase in j
the probability or consequences of an accident previously evaluated.
Reducing the required minimum channels OPERABLE for radiation monitors GT-RE-31 and 32 does not significantly increase the probability or consequences on an accident previously evaluated.
One channel will be OPERABLE or ACTION 26 will be followed.
This ACTION requires containment purge valve closure.
This assures the fulfillment of the safety function of Table 3.3-6 Functional Unit 1.a..
Increasing the allowed outage times for ACTIONS 27 and 30 will not significantly increase the probability or consequences of an accident previously evlauated.
This change allows an extended time period for the diagnosis and repair of inoperable radiation monitors to which these ACTION statements are applicable.
During the allowed outage time, redundant radiation monitors remain OPERABLE.
If no channels are OPERABLE only one hour is allowed until initial operation of the Control Roon Emergency Ventilation System or the Emergency Exhaust System, es appropriate, is established.
2.
The proposed changes do not create the possibility of a ne'. or different kind of accident from any previously evaluated.
The proposed changes do not involve any change in radiation monitor setpoints or physical design of the involved systems.
There are no new failure mechanisms associated with the proposed changes.
The proposed changes will allow additional time for the diagnosis and repair of inoperable radiation monitors. The proposed allowed outage times remain consistent with the requirements for overall system availability.
3 The proposed changes do not involve a significant reduction in a margin of safety. These changes do not affect any Technical Specification margin of safety. The proposed changes do not alter the manner in which safety limits and limiting safety system setpoints are determined.
Redundant radiation monitors remain OPERABLE during the extended allowed outage time and under the revised minimum OPERABLE channels Requirement Based on the above discussions and those presented in Attachment I, it has been determined that the requested Technical Specifiestion revisions do not involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; or create the possibility of a new or different kind of accident or condition over previous evaluations; or involve a significant reduction in a margiu of safety.
Therefore, the requested license amendment does not involve a significant hazards consideration.