ML20216F712

Application for Amend to License NPF-42,alleviating Need for Enforcement Discretion Granted by NRC on 970905

ML20216F712
Person / Time
Site:	Wolf Creek
Issue date:	09/06/1997
From:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20216F717	List: ML20216F712 ML20216F731
References
GL-96-01, GL-96-1, WM-97-0111, WM-97-111, NUDOCS 9709120077
Download: ML20216F712 (13)

Text

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W@ NUCLEAR LF CREEK OPERATING C Otto L Maynard President and Chef Executive Omcer i September 6, 1997 I

WM 97-0111 U. S. Naclear Regulatory Commission ATTN Document Control Desk Mail Station F1-137 Washington, D. C. 20555

Reference:

WCNOC Letter WO 97-0093, dated September 5, 1997, from

- C. C. Warren, WClJOC, to the USNRC 4

Subject:

Docket No. 50-482: Emergency Technical Specification Amendment Application for Technical Specification Section 4.8.1.1.2.g ,

P Geit1emen:

This letter transmits an application for an emergency amendment to Facility i Operating License No. HPF-42 for Wolf Creek Generating Station (WCGS). Wolf ,

Creek Nuclear Operating Corporation (WCNOC) requests that this request be l reviewed under the emergency situation provisions of 10 CFR 50. 91 (a) ( 5) . This

. emergency amendment is necessary to alleviate the need for the Enforcement Discretion granted by t he NRC on September 5, 1997, as described below.

On September 4, 1997, as a result of reviews undertaken in response to Generic Letter 9f-01, " Testing of Safety Related Logic Circuits," and information l l r'ceived .' rom another plant, WCNOC determined that existing surveillance testing '

rla u , completely verify all of the above Technical Specification surveillar.ce requirements. Technical Specification 4.0.3 was entered at 1906 CDT on Septe .>er 4, 1997, for the missed surveillances, j The Reference requested Enforcement Discretion to permit the one-time

, performance, at power, of the surveillance testa described above, which are required to be performed with the unit shutdown. The Enforcement Discretion also allows an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complet e those tests. This request for enforcement discretion was verbally approved by the NRC on September 5, 1997 As discussed in the Reference, this action was required to permit the completion of the testing described above without having to shut down the unit.

This license amendment request adds a footnote to Technical Specification Surveillance Requirements 4.8.1.1.2.g.2)c)2), 4. 8.1.1. 2. g . 3 ) d) and j 4.8.1.1.2.g.4)d). This footnote would 1) allow one-time testing of the /

blocking / time delay contacts associated with relays K1102, K4102, K1117, K4117, K1118, and K4118, at power, and 2) oxtend the provisions of Technical 1 Specification 4.0.3 to complete testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, to permit completion of the testing of these contacts by 1906 hours0.0221 days <br />0.529 hours <br />0.00315 weeks <br />7.25233e-4 months <br /> on September 6, 1997 A Safety Evaluation of the proposed change is provided in Attachment I, andT ~

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Attachment II provides a No Significant Hazards Consideration Determination. .

Attachment III is the Envi ronment al Impact Determination for the proposed change, and the marked-up Current Technical Specification pages for t his request are provided in Attachment IV.

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WM 97-0111 Page 2 of 2 In accordance with 10 CFR 50.91, a copy of this revision to our original application, with attachments, is being provi Jed to the designated Kansas State Official.

If you have any questione concerning this matter, please contact me at (316) 364-8831, extension 4000, or Mr. Richard D. Flannigan, at extension 4500.

Very truiy you s, h i Otto L. Maynard OLM/dle Attachments 1 -- Safety Evaluation II -- No Significant Hazards Consideration Determination ,

III -- Environmental Impact Determination IV -- Proposed Current Technical Specification Change ces V. L. Cooper (KDHE), w/a W. D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a i

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m STATE OF RANSAs )

') ss-Couwrr or corrav )

~ Otto L. Maynard, of lawful age, being first duly sworn upon oath says that he is President and Chist Executive of ficer of Wolf - Creek Nuclear ~ Operating Corporations that he has -read the foregoing document and=knows:the content thereof; that he has executed that same for and on behalf of said Corporation with full power and euthority to do aos-and that the facts therein stated are true a.id correct to the best of his knowledge, information and belief.

9y A///1NN Otto . Mayn/rd [~

President and Chief Executive Officer SUBSCRIBED and sworn to before me this [ph dayofhp/tmM(, 1997, ilii 0 bzij

" * " I'#

JULIE A. DALE g m .sWe enene

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Expiration oate /o/20hr

Att echtn:nt I to WM 97-0111 P gs 1 of 5 1 4 I

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ATTACHMENT I SAFETY EVALUATION e

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Attachment I to kH 97-0111 Page 2 of 5 Safety Evaluation proposed Change This request for an emergency technical specification amendment proposes to revise Technical Specification 3/4.8.1, "A.C. Sources Operating," to add a footnote to surveillance Requirements 4.8.1.1.2.g.2)c)2), 4.8.1.1.2.g.3)d),

and 4.8.1.1.2.g.4)d). The footnote would state "One-time testing of the blocking / time delay contacts associated with relays K1102, K4102, K1117, K4117, K1118, and K4118 at power .

is permitted. The provisions of Technical Specification 4.0.3 to complete testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is extended to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to permit cornpl et ion of the testing of these contacts by 1906 hours0.0221 days <br />0.529 hours <br />0.00315 weeks <br />7.25233e-4 months <br /> on a September 6, 1997."

A Request for Enforcement Discretion on this subject was submitted by letter  !

dated September 5, 1997. This Request for Enforcement Discretion was discussed with and verbally approved by the IJRC on September $, 1997.

Background

Technical Specification 4.8.1.1.2.g.2)c)2) requires that. each Emergency Diesel Conerator (EDG) be demonstrated operable, at least once per 18 months, during shutdown, by verifying, on an actual or simulated loss-of-of f site power (LOOP) signal, that the EDG auto-starts from standby conditions and energizes the auto-connected shutdown loads through the shutdown sequencer.

Technical Specification 4.8.1.1.2.g.3)d) requires that each EDG be demonetrated operable, at least once per 18 months, during shutdown, by verifying, on an actual or simulated Safety Injection Actuation Signal, that nach EDG auto-starts from the standby fondition and the of f sit e power source energizes the auto-connected (accident) loads through the LOCA sequencer.

Technical Specification 4.8.1.1.2.g.4)d) requires that each EDG be demonstrated operable, at least once per 18 months, during shutdown, by verifying, on a simulated LOOP in conjunction with a simulated Safety Injection Actuation Signal, that each EDG auto-starts from the standby condition and energizes the emergency busses with perrnanently connected loads within 12 seconds, and energizes the auto-connected emergency (accident) loads t hrough t he LOCA sequencer.

On September 4, 1997, as a result of reviews undertaken in response to Generic Letter 96-01, " Testing of Safety Related Logic Circuits," and information received from another plant, Wolf Creek Nuclear Operating Corporation (WCNOC) determined that the existing surveillance testing procedures did not completely verify all of the above Technical Specification surveillance requirements. Specifically, it was discovered that certain relay contacts required _ to open have not been tested during performance of surveillance procedure STS KJ-001A/D, " Integrated Diesel Generator Safeguards Aduation Test Tr ain A/B." The contacts in question are actuated by relays K1102, K4102, K1117, K4117, K1118 and K4118. The current testing process, implemented through STS KJ-001A/B, has not demonstrated the function of the contacts because there are other contacts in series that could also be open during the testing.

These relay contacts provide a blocking / time delay function for start of the Component Cooling Water (CCW) pumps, Essential Service Water (ESW) pumps, and the Motor Driven Auxiliary Feedwater (MDAFW) pumps. On a loss of offsite power, the CCW, ESW, and MDAfH pumps are shed from the safety busses and then

At t achnont I to WM 97-0111 Page 3 of 5 loaded in sequence to the EDGs. The relay contacts' blocking /tirne delay function ensure that no matter what the start demand is for the pumps, they are not started until the parallel contacts of the load sequencer close to start the purrp at the required tithe increment.

The functionality of the relays has been demonstrated during prior performances of procedure STS KJ-001A/B. For exartple, relays K1102 and K4102 have successfully actuated load shed and tripped the 11 8 bus normal feeder breaker, relays K1117 and K4117 have successf ully actuated valves ETHV-42 and EFHV-40, and relays Kil18 and K4118 have successfully actuated ETHV-59 and EFHV-60. However, testing of the specific contacts should oe conducted to provide complete testing and absolute assurance that load sequencing will function as designed.

Technical Specification 4.0.3 was entered at 1906 CDT on September 4, 1997, due to the discovery that the contacts had not been adequately tested in accordance with the technical specification- surveillance requirements.-

Technical Specification 4.0.3 allows the ACTIOt1 requirements of the applicable sections to be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the

- surveillance when the allowable outage time limits of the ACTJoli requirernents are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, Technical Specification 4.8.1.1.2.g requires that the surveillance testing be *>erformed once every 18 months during shutdown. 'l hu s , these surveillances cannot be perf ormed at power under the current technical specification requirements.

Therefore, WCtJOC requested Enforcement Discretion on September 5, 1997, to permit one-time testing of these contacts while the plant is at power. WCt10C also requested an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, beyond the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> permitted by Technical Specification 4.0.3, to complete this testing. This request was verbally granted by the 14RC on September 5, 1997 A preliminary cause for this condition is an error made during t', initial development of the surveillance procedure in that these contacts were not recognized as requiring testing. This error resulted in not performing the surveillance testing for the subject relay contacts, as required, in turn resulting in the missed surveillances. As indicated, under the current technical specifications, these surveillances cannot be performed with the unit at power. Thus, this proposed change is necessary to permit the one-time performance of these surveillances at power, without having to shut down the unit. Since the testing procedure did not identify the need to specifically test the subject relay contacts, this situation could not have been avoided.

WCt10C has initiated the proper corrective action documents to further research the root cause, determine corrective actions to prevent recurrence, and investigate generic aspects of the event.

The missed surveillances cannot be performed under current technical specification requirements without shutting down the unit, and, per Technical Specification 4.0.3, the missed surveillances have to be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery. This proposed amendment request meets the energency situation provisions of 10 CFR 50. 91 (a) ( 5) in that, without the proposed change, a shutdown of the ur,it is required.

Evaluation Design Bases function:

The standby power supply for each safety-related load group consists of one diesel generator, complete with its accessories and fuel storage and transfer systems. The standby power supply is capable of supplying essential loads necessary to reliably and safely shutdown and isolate the reactor. The diesel v ,,, ,, er- -- e y- .e- ,- - - - - - - , _ --w-,, ,,,n ,,r v g- - - v,. , , - . , ~,

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Attachment I to WM 97-0111 Page 4 of $

ger$erator s are electrically isolated from each other. Power and control cables for the diesel generators and associated switchgear are routed to maintain physical _ separation, katings for diesel generator sets are established in order to satisfy the requirements set forth in Regulatory Guide 1.9. The diesel generator loads are determined on the basis of nameplate rating, pump pressure and flow conditions,- or pump runout conditions. The continuous rating of the diesel generator is based on the maximum total load requirei at any time. The Load Shedding and Emergency Load Sequencing (NF) System removes selected loads from the Class 1E ousses under degraded bus voltage ccnditions, or upon - the -

presence of a safety injection signal, and actuates equipment fed from these busses in a. predetermined sequence following degraded bus voltage conditions or in the presence of a loss-of-coolant accident (LOCA).

The load shedding portion of the HT system removes selected loads under degtaded voltage conditions on the 4160 volt Class IE busses. Loads are then actuated in programmed intervals by the sequencing portion of the system such that the voltage of the busses does not fall below 75 percent of rated voltage and the frequency:does not fall below 95 percent of rated frequency. All of the non-Class IE loads supplied by the Claes IE busses, with the exception of the non-vital instrument busses, are shed automatically upon the presence of a safety injection signal. These loads must then be manually re-energized, if required. In the event preferred power is lost following a LOCA, the load sequencer will function to shed selected loads and automatically start the associated standby diesel generator. Load sequencers then function to start the required Class IE loads in programmed time increments.

The contacts in question are actuated by relays K1102, K4102, K1117, K4117, K1118 and K4118. The relay contacts provide a blocking / time delay fonction for starting of the CCW, ESW, and MDAFW pumps. On a loss of of fsite power, the CCW, ESW, and MDAEM pumps are shed from the safety busses and then loaded in sequence to the EDGs. These contacts ensure that no matter what the stert demand is for the pumps, they are not started until the required time increment elapses.

Impact on Nuclear Safety:

The integrated EDG and Engineered Safety Features Actuation test is performed during shutdown because of a potential that this surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state rperation and unit safety systems. The testing proposed to be done at power is only a partial test of the subject Load Shedding and Emergency Load Sequencing System relay contacts while at powers it does not duplicate the integrated EDG and Engineered Safety Features Actuation test and will_ not cause any perturbation to the electrical distribution systems that could challenge steady state operation or unit safety systems.

For the relay contacts associated with the ESW and CCW pumps, testing will be accomplished by-actuating slave relay =K645A/B and verifying that the blocking contact on-relays K1117, K4117, K1118 and K4118 change state. The testing of these contacts at power will- be performed in accordance with specific procedut os approved f or this purpose.

For the

• ay_ contacts associated with the - HDAFW pumps, testing will be-accomplia by isolating-the relays (K1102, K4102) from their normal power .

supply by iting leads, and actuating the relay using a portable power source l to verify (ne contacts change state for.the specified time period. During the ,

test for the "A" MDArW pump the leads from relay K1102 that shed NB0112, "NB01 '

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. Attachment I to.WM-97-0111 Page 5=of-5 4 Normal = Feeder Dreaker," must - be lif ted - to preclude tripping . thic- breaker.

Improper conduct - of t th9 test could result in tripping NB0112, . "NB011 Normal Feeder Breaker." However, any effects would be mitigated by implementation of existing plantLoff-normal procedates. This-activity will be administratively--

controlled to ensure removal and restoration are safely accomplished.

i Probabilistic Safety Assessment (PSA) Evaluations-A - quantitative probabilistic evaluation was performed to ' estimate the impact

!- of performing the subject testing in Mode 1 versus performance in Mode 3.

Using both Mode 1 and Mode 3 plant operation as starting points, the imoact on plant risk associated with performance if the subject tv.ating was-considered.

For Loth Mode 1 and Mode 3 plant operation, the relative increase in risk over the baseline Core Damage Frequency (CDF) value (no equipment out of service) due to removing plant equipment from service for the short test duration, was nearly identical. .This would be expected as the equipment being removed from-service for' testing has the same type of functional impact for postulated '

initiating events in both plant operational modes.

The' likelihood of experiencing transient-related plant .onditions, such as an inadvertent safety system actuation or a plant system alignme it failure, is

- qualitatively considered - to be :2 lightly greater dur ing a plant shutdown and startup evolution than for continued at-power operation. A minor annual CDF 4 re. duction would be experienced by operation in Mode 3 instead of Mode-1 for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. Howucer, on'a qualitative basisi it is considered that this

reduction would be ofreet by the increased likelihood of experiencing an event i of the type that-might~present a challenge to.the relay contac;s in question prior to performance of the testing. Therefore, performance of the subject testing in Mode 1 is not considered risk significt.nt.

l' Based on the above discussions and the no significant hazards consideration

determination presented in Attachment II, the proposed change _does not '

increase the probability of occurrence or the consequences of an accident or i' malfunction of equipment important to safety previously evaluated in the

- safety-analysis reporti or create a possibility for an accident or malfunction l- . of a different type than any previously evaluated in the safety analysis i raport; or reduce the margin . of safety as defined in the basis for any technical specification. Therefore, the proposed - change does not adversely '

a f f e':t or endanger the health or safety of the general public or involve a-significant safety hazard.

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. Attschment 11 to WM 97-0111 Paga l'of 3 ATTACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

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. Attachment II to WM 97-0111-1 Page 2 of 3 i

, s .No Significant Hasards Consideration Determination .

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This request for an - emergency technical specification amendment proposes to revise Technical Specification 3/4.8.1, "A.C. Sources operating," to add a footnote to Surveillance - Requirements - 4.8.1.1.2.g.2)c) 2), 4.8.1.1.2.g.3)d),

and 4.8.1.1.2.g.4)d). . The footnote would stato ,

• 0ne-time-testing of the blocking / time delay contacts associated with relays K1102, K4102,_K1117, K4117, K1118, and-K4118 at power is permitted. The provisions of Technical Specification 4.0.3 to

-complete testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is extended to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to permit '

completion of the testing of these contacts by 1906 hours0.0221 days <br />0.529 hours <br />0.00315 weeks <br />7.25233e-4 months <br /> on

' September 6, 1997."  !

A Request for Enforcement Discretion on this subject was submitted by letter  ;

dated September 5, 1997. This Request. for Enforcement Discretion was ,

discussed with the NRC Region IV Office ind Office of Nuclear Reactor ,

, Regulation and verbally approved on September 5, 1997.

Standard I'- Involves A Significant Increase In The Probability .Or

Consequences Of An Accident Previously Evaluated i

i This proposed change does not change the function or performance requirements for the Load Shedding end Emergency Load Sequencing. System, as described in the Updated Saf ety Analysis Report (USAR) and the Technical Specifications.

Testing these relays at power will not cause any degradation in system performance, nor will it increase the number of challenges - to equipment assumed to function during an accident situation. The testing will. require

related equipment to be declared inoperable for the duration of each test, but these--durations will be much less than those allowed by the applicable Further, the proposed change would Technical Specification Action Statements.

prevent an unnecessary unit shutdown which could result in a reactor transient '

and a unwarranted challenge of the safety-related systems. This is a one-time test, and future testing will be performed in accordance with the requirements specified in the Technical Specifications.

Thus, the proposed change will not resultz in an increase in the consequences 1 of, or an increase in the probability of occurrence of, any accident previously evaluated.

l Standard II Create The Possibility of A New Or Different Kind- Of Accident From Any Previously Evaluated.

The Load - Shedding and Emergency- Load Sequencing System will continue to ,

perform in a manner consistent with the - assumptions in the USAR. No new l scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced. There will be no adverse effects or challenges imposed on any. safety-related system as a resuJt of this request. Therefore, the possibility of a new or different kind of accident is not created.

Standard III Involve A Significant Reduction In The Margin of Safety The purpose of this request is to allow WCNOC the ability to perform a one-time partial test of the subject Load Shedding and Emergency Load Sequencing System relay contacts while at-power. This testing will demonstrate complete-compliance ~ with Technical Specification 3/4.8.1 without having to shut down the unit. This activity will not affect any system or. component setpoints or 9- ,--- w'4 - +,.yi.ib -,a yr y p - -m y.+ .-c,-e- .- - -

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Attachment II to WM,97-0111 t Page 3 of_3'

, safety ' limit settings cassociated with the Load . Shedding and Emergency Load Sequencing System. No new accident scenarios, transient precursors, failure mechanisms, or limiting single f ailures_ are introduced. There will be no significant adverse effects or challenges imposed on-any safety-related system ,

as a result of this request. This-request will not result in a significant--

reduction in the margin of safety.

Therefore, WCNOC has determined that the proposed change does nota involve a significant increase -in the: probability or consequences of an accident or other adverse condition over previous evaluations; create the possibility of a ,

.new or different kind of accident or condition over previous evaluations;.nor_

involve a significant reduction in a margin of safety. Therefore, this <

emergency amendment request meets - the requirements of 10 CFR 50. 92 (c) , and

• does not involve a significant hazards consideration.

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Attechmant III to WM 97-0111 Pcge 1 of 2 e

ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION

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. Attachment-111 to WM 97-0111 Page-2--of 2.

s N Environmental Impact Determination

' ~

10- CFR -- 51.22 (b) - specifies - the - criteria for categorical exclusions _ from the 1 requirement - for a specific environmental assessment per 10 CFR 51.21. This ,

t artendment request . meets .the criteria specified in 10 CFR 51. 22 (c) (9) as specified belows.

4 (i)= the amendment involves no significant hazards consideration As l demonstrated in Attachment II, the proposed change does not involve any significant hazards consideration. .

t (ii) = there is no significant change in the types or significant increase in the amounts of any effluents that may be released '

offsite-a-

The proposed change does not involve a change to the facility or operating i

. procedures that would cause an increase in the amounts of effluents or create new types of effluents.- .The proposed change does not involve changes to any instrumentation setpoints, system operating parameters, or system accident mitigation capabilities, nor does this change affect the probability of any event initiators. Thus, the proposed' change does not reduce the margin of s

safety to any licensed design parameter.

(iii) there is no significant increase in individual or cumulative occupational radiation exposure The proposed change would not adversely affect the operation..of the reactor, _

< and would not affect any system that would affect occupational radiation exposure. The proposed change does not create additional exposure to personnel nor affect levels of radiation present. The proposed change will not result in any increase in individual or cumulative occupational radiation exposure.

Based on the above, it is concluded that there will be no impact on the 4

environment resulting from the proposed change and that the proposed change meets' the criteria specified in 10 CFR 51.22 for a categorical exclusion f rom the requirements of- 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission.

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