ML20247F855

Application for Amend to License NPF-42,revising TS 3/4.3.2, Table 3.3-3,ESF Actuation Sys Instrumentation

ML20247F855
Person / Time
Site:	Wolf Creek
Issue date:	05/08/1998
From:	Warren C WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247F858	List: ML20247F855 ML20247F861
References
WO-98-0034, WO-98-34, NUDOCS 9805200069
Download: ML20247F855 (10)

Text

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'o WQLF CREEK NUCLEAR OPERATING CORPORATION Clay C. Warren Chief Operating Offcer May 8, 1998 WO 98-0034 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: Pl-137 Washington, D. C. 20555

Reference:

1) Letter ET 97-0050 dated May 15, 1997 from R. A. Muench, WCNOC to NRC

Subject:

Docket No. 50-482: Application for Exigent Amendment to Technical Specification 3/4.3.2, Table 3.3-3, Engineered Safety Features Actuation System Instrumentation Gentlemen:

This letter transmits an application for amendment to Facility Operhting License No. NPF-42 for the Wolf Creek Generating Station (WCGS). This iequest proposes to revise Technical Specification 3/4.3.2, Table 3.3-3, Furictional Unit 7.b., RWST Level - Low-Low Coincident With Safety Injection, by adding a new Action Statement.

Wolf Creek Nuc1x Operating Corporation (WCNOC) requests that this proposed license amendm or request be processed under the exigent situation provisions of 10 CFR 50. 91 ta) (6) . Action Statement 16 for Functional Unit 7.b. requires j that with the number of OPERABLE channels one less than the Total Number of I Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is met.

The quarterly Analog Channel Operational Test (ACOT) for Functional Unit 7.b.

is required by Surveillance Requirement 4.3.2.1. The plant configuration for a Refueling Water Storage Tank (RWST) analog channel will not allow the surveillance test to be performed when the channel is in a bypassed condition.

The surveillance requirement for this channel is required to be completed by May 29, 1998. Therefore, WCNOC requests this license amendment request be processed on an exigent basis by May 26, 1998 to provide some margin should equipment problems occur during the surveillance testing.

A Safety Evaluation for the proposed license amendment request is provided in Attachment I; a No Significant Hazards Consideration Determination, in l Attachment II. Attachment III is the related Environmental Impact Determination. Marked up pages are provided in Attachment IV (for current Technical Specifications) and in Attachment V (for Improved Technical Specifications and Bases submitted by Reference 1).

9805200069 980508 .' I PDR P ADOCK 05000482 \I

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h PO. Box 411/ But;ington, KS 66839 / Phone; (316) 364-8831 An Equal Opportumty Einplove, M r HC vtT e-______-_-___._______________.____-___ _ _ _ _ _ . _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _

l WO 98-0034 Page 2 of 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Kansas State Official.

.If you have questions concerning this matter, please contact me at (316) 364-8831, extension 4485 or Mr. Michael J. Angus at extension 4077 Ver' truly yoyrs, C1 C. Warren CCW/rlr Attachments: I - Safety Evaluation II - No Significant Hazards Consideration Determination III - Environmental Impact Determination IV - Proposed Current Technical Specification Change V - Proposed Improved Technical Specification Change i i

ec: V. L. Cooper (KDHE), w/a {

W. D. Johnson (NRC), w/a j E. W. Merschoff (NRC), w/a l J. F. Ringwald (NRC), w/a I K. M. Thomas (NRC), w/a  !

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i STATE OF KANSAS )

) SS 3 COUNTY OF COFFLL ) I Clay C. Warren, of lawful age, being first duly sworn upon oath says that he is Chief Operating Officer of Wolf Creek Nuclear Operating Corporation; 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 authority to do so; and that the facts therein stated are true and correct to

-the best of his knowledge, information and belief.

f BY . -- __

Clay . Warren Chief erating Officer SUBSCRIBED and sworn to before me this @Y day of MQ , 1998.

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Notary Pu'blic e mL -

MARY E. GIFFORD Notary Public State of Kansas My Appt. Empires h2/D9h999 Expiration Date {k OS ISS

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, Attachment I to WO 98-0034

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l ATTACHMENT I

SAFETY EVALUATION

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. Attachment I to WO 98-0034 Page 2 of 3 Safety Evaluation Proposed Changes This license amendment request proposes to revise Wolf Creek Generating Station (WCGS) Technical Specification Functional Unit 7.b., RWST Level - Low-Low Coincident With Safety Injection, Action Statement in Table 3.3-3, Engineered Safety Features Actuation System Instrumentation. Specifically, new Action Statement 30, which would be entered for an inoperable Refueling Water Storage Tank (RWST) analog channel, allows for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place an inoperable RWST analog channel in a bypassed condition and allows for surveillance testing of an additional analog channel of Functional Unit 7.b.,

by placing the channel in a tripped condition for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Background

Action Statement 16 for Functional Unit 7.b. requires that with the number of OPERABLE channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is met. An RWST analog channel can be placed in a bypassed condition by removing the bistable card. However, removal of the bistable card prohibits the performance of the Analog Channel Operational Test (ACOT). The ACOT for Functional Unit 7.b. is required by Surveillance Requirement 4.3.2.1. The quarterly ACOT is performed by declaring the RWST analog channel inoperable and placing the channel in the test position. WCNOC personnel identified on May 5, 1998, during the procedure brief for performance of surveillance procedure STS IC-201, " Analog Channel Operational Test 7300 Process Instrumentation Protection Set 1 (Red)," that the RWST level channel in the test position actually places the channel in a

" tripped" condition, which is contrary to Action Statement 16 requirements for an inoperable channel.

Evaluation During the injection phase of a Loss of Coolant Accident (LOCA), the RWST is the source of water for all Emergency Core Cooling System (ECCS) pumps. A low low-l level in the RWST, coincident with a Safety Injection (SI) signal, provides protection against a loss of water for the ECCS pumps (Residual Heat Removal Pumps) and indicates the end of the injection phase of the LOCA. The RWST is equipped with four level transmitters. These transmitters provide a two-out-of-four logic to initiate the protection function actuation.

Automatic switchover occurs only if the RWST low low-l level signal is coincident with an SI. This prevents accidental switchover during normal operation. Accidental switchover could damage ECCS pumps if tn( are attempting to take suction from empty containment recirculation sumps.

The RWST Level - Low-Low Coincident With Safety Injection function (Functional Unit 7.b.) must be OPERABLE in MODES 1, 2, 3, and 4 when there is a potential fer a LOCA to occur, to ensure a continued supply of water for the ECCS pumps.

Functional Unit 7.b provides actuation of switchover to the containment recirculation rumps. This Function requires the bistables to energize to perform their required action. The failure of up to two channels will not prevent the operation of this Function. Placing a failed channel in the tripped condition could result in a premature switchover to the sump prior to the injection of the minimum volume from the RWST. Placing the inoperable channel in a bypass condition results in a two-out-of-three logic configuration, which satisfies the requirement to allow another failure without disabling actuation of the switchover when required. Restoring the channel to OPERABLE status or placing the inoperable channel in the bypass condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is sufficient to ensure that the Function remains OPERABLE, and minimizes the time that the Function may be in a partial trip condition. The 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> completion time in new Action Statement 30 is justified i

., Attachment I to WO 98-0034 Page 3 of 3 in WCAP-10271-P-A, Supplement 2, B'evision 1, " Evaluation of Surveillance

. Frequencies , and Out of' Service "imes for the Engineered Safety Systems Actuation System." If the channel cannot be returned to OPERABLE status or placed in the bypass conditior, Technical Specification 3.0.3 would be entered.

Wolf Cred does not have the et.pability to perform surveillance testing on a routine basis with an RWST analog channel in a bypassed condition. These channels are not designed for testing in the bypassed condition for Action Statement 16 to be applicable. New Action Statement 30 would allow 6 ho' to perform surveillance testing once the channel was declared inoperable - re it would have to be placed in a bypass condition. With one' channel inoperable and the minittum channels-OPERABLE requirement met, one additional channel may be plaad in trip for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing. Prior surveillance testing of these normally de-energized, energize-to-actuate channels has beer. per formed with the tected channel's bistable in the tripped condition.

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 malfunction of equipment important to' safety previously evaluated in the safety analysis report; or create a possibility for an accident or malfunction of a different type than any previously~ evaluated in the safety analysis report; or reduce the margin of safety as defined in the basis for any technical specification. Therefore, the proposed change does not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard, l

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, Attachment II to WO 98-0034 Page 1 of 2 ATTACHMENT II l

NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 1

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. Attachment II'to WO 98-0034 Page 2 of 2 No Significant Hazards Consideration Determination Proposed Change This license amendment request proposes to revise Wolf Creek Generating Station (WCGS) Technical Specification Functional Unit 7.b., RWST Level - Low-

, Low Coincident With Safety Injection, Action Statement in Table '3;3-3,

, Engineered - Safety . Features . Actuation System Instrumentation. Specifically, t

.new Action Statement 30, which would be entered for-an inoperable Refueling:

l Water Storage Tank (RWST) analog channel, allows for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place an-L inoperable RWST analog crannel in a bypassed condition and allows- for

surveillance testing of an additional analog channel of Functional Unit 7.b.,

l by placing the channel in a tripped condition for up to 4 hourn.

The following sections discuss the proposed change under the three standards of 10 CFR 50.92.

Standard .I -

Involves a Significant Increase in the Probability or-Consequences of an Accident Previously Evaluated The new Action' Statement 30 for Functional ~ Unit 7 b. of Table 3.3-3, Automatic Switchover to Containment Sump or RWST Level Low-Low Coincident with Safety i Injection, reflects the current plant design and i testing practices. As l discussed in License Amendment No. 43 and associated'submittals, the increase in allowed outage ' time was ' evaluated and the associated unavailability and '

risk was shown to'be equivalent to, or less than, that of other functional units evaluated in WCAP-10271, Supplement 2, Revision 1. The proposed change does not change any previously evaluated accident and therefore does not involve an increase in the probability or consequences of an accident

[ previously evaluated.

Standard II - Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed change will not result in physical alteration to any plant system nor will there be a change in the method by which any safety-related plant system performs ~ its safety function. The proposed change does not-alter the functioning -of the Engineered Safety Features Actuation System (ESFAS) or l

change the manner in which the ESFAS provides plant protection. Therefore, '

there is no possibility of a new or different kind of accident from any accident previously evaluated.

Standard III - Involve a Significant Reduction in the Margin of Safety l l

The proposed change does not alter any safety limits, limiting safety system settings, or limiting conditions for operation. The proposed change will not involve a significant. reduction in any margin of safety.

Conclusions 1

-Based on the above discussions, it has been determined that the ' requested l . technical specification revision does not involve a significant increase in I

the probability of Lconsequen,.us of an accident or other adverse conditions  ;

over previous evaluations; or create the possibility of a new or different l kind of accident or condition over previous evaluations; or involve a g significant reduction in a margin of safety. Therefore, the requested license amendment does not involve a significant hazards consideration.

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Attachment III to WO 98-0034

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ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION l

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Attachment III to WO 98-0034

. Page 2 of 2 Environmental Impact Determination 10 CFR 51.22(b) specifies the criteria for categorical exclusions from the requirement for a specific environmental assessment per 10 CFR 51.21. This I amendment request meets the criteria specified in 10 CFR 51. 22 (c) ( 9) as specified below:

(i) the amendment involves no significant hazards consideration As demonstrated in Attachment II, the proposed changes do not involve any significant hazards considerations.

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-(ii) there is not significant change in the types or significant increase in the amounts of any effluents that may be released offsite The proposed change does not invo10e 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.

(iii) there is no significant increase in individual or cumulative occupational radiation exposure ,

l The proposed change reflects the current plant design and testing practices. l This change has no relation to occupational radiation exposure, either I individual or cumulative.

Based on the above, it is concluded that there will be no impact on the environment resulting from this change and the change meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission.

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