ML20247H889
| ML20247H889 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/11/1998 |
| From: | Warren C WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WO-98-0046, WO-98-46, NUDOCS 9805210278 | |
| Download: ML20247H889 (3) | |
Text
.
WQLF CREEK NUCLEAR OPERATING CORPORATION Clay C. Warren Chief Operating Officer May 11, 1998 WO 98-0046 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station: P1-137 Washington, D. C.
20555
Reference:
Letter WO 98-0034 dated May 8,
1998 from C.
C.
- Warren, WCNOC to NRC
Subject:
Docket No.
50-482:
Supplemental Information Regarding Exigent Amendment to Technical Specification 3/4.3.2, Table 3.3-3 Gentlemen:
Reference 1 provided Wolf Creek Nuclear Operating Corporation's (WCNOC) request for a License Amendment pertaining to Refueling Water Storage Tank (RWST) level instrumentation (Technical Specification Table 3. 3-3, ' Functional Unit 7.b.,
RWST Leve] - Low-Low Coincident With Safety Injection).
In that letter, WCNOC requested that the license amendment be issued on an exigent
' basis.
In a telephone conversation with the NRC Project Manager on May 9,
- 1998, additional information was requested concerning why this exigent situation occurred and why the situation could not be avoided.
This letter provides requested additional information regarding the rationale for that exigent request.
On May 5,
1998, MCNOC Control Room personnel were reviewing the Technical Specifications associated with the RWST level instrumentation and the performance of surveillance procedure, STS IC-201, " Analog Channel Operational Test 7300 Process Instrumentation Protection Set 1 (Red)."
During that review, Control Room personnel identified that, when the RWST level channel is taken into the " test" position, the channel is actually put in a tripped condition.
However, the associated Technical Specification Action Statement (TS 3.3-2, Functional Unit 7.b.,
Action 16) iur an inoperable channel indicates that the inoperable channel must be placed in the bypass condition.
There is no time limit allowance for placing an inoperable channel in the bypass condition associated with Action 16.
Since the surveillance would render the channel inoperable, and there is no way of performing the surveillance with tne channel in the bypass condition, WCNOC personnel determined that a Technical Specification amendment would be needed to allow l
the surveillance test to be completed.
The RWST level instrumentation analog channel operational test (STS IC-201) was last performed on February 5,
1998.
The surveillance is required by Technical Specification Surveillance Requirement 4.3.2.1 to be performed on a quarterly basis.
Taking into account the extra 25% allowance from Technical l /
Specification 4.0.2, this surveillance would go overdue, rendering the channel l
inoperable, on May 31, 1998.
The first surveillance test (STS IC-202) for an RWST level channel _would ao overdue on May 29, 1998 and another channel 9805210278 980511 hgOI PDR ADOCK 05000482 p\\
PDR P
~~ ~
PO. Box 411 I Burhngton, KS 66839 / Phone: (316) 364 8831 An Equal Opportunity Employer M FHCNET
WO 98-0046 Page 2 of 2 surveillance test (STS IC-203) will go overdue on May u,
1998. With two channel's being inoperable, entry into Technical Specificat ;cn 3.0.3 would.be required, forcing shutdown of Wolf Crc?k Generating Station (WCGS).
The time between initial discovery of this event (May 5, 1998) and the date when a forced shutdown of WCGS (May 30, 1998) is less than 30 days; therefore, there is not enough time for normal processing of an amendment.
WCNOC believes that, given the circumstances surrounding the discovery of this event and the complexity of the instrumentation function, the Corporation has made a best effort to submit a timely application for this amendment.
WCt!OC has not delayed any actions in order to create the need for exigency and therefore "take advantage" of the procedure described in 10 CFR 50.9} for exigent amendments.
WCt10C belleses that this. exigent amendment
'. s unavoidable, and meets the criterion of 10 CFP 50. 91 (a) ( 6 ) for an exigent request.
If you have questions concerning this matter, please centact me at (316) 364-8831, extension 4485 or Mr. Michael J. Imqus at extension 4077.
Very truly yourc, C1 C. Warren CCW/rir cc:
V.
L.
Cooper (KDHE), w/a W.
D.
Johnson (NRC), w/a E.
W.
Merschoff (NRC), w/a J.
E.
Ringwald (NRC), w/a K.
M. Thomas (NRC), w/a j
l l
1
STATE OF KANBAS
)
)
BB COUNTY or CorrEY
)
' 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.
By Clay-C.
arren Chief erating Officer SUBSCRIBED and sworn to before me this ff day of hg
, 2938.
A7 b
bh l
LINDA M. OHMIE Notary Public Notary Pub 5e. Stato et Kansas pmt exe.s f-3/- 9F -
R4 l"W Expiration Date i
.