ML23220A422

Supplement to License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements

ML23220A422
Person / Time
Site:	Wolf Creek
Issue date:	08/08/2023
From:	Boyce M, Lane L Wolf Creek
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
000048
Download: ML23220A422 (1)

Text

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Nuclear Operating Corporation Michael T. Boyce Vice President Engineering August 8, 2023 000048 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Reference:

Letter ET 22-0010 dated August 2, 2022, from M. T. Boyce, WCNOC, to USNRC, License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements

Subject:

Docket No. 50-482: Supplement to License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements Commissioners and Staff:

This letter is a supplement to the Reference in which Wolf Creek Nuclear Operating Corporation (WCNOC) submitted an application to revise the Renewed Facility Operating License No. NPF-

42. The LAR requested approval to make changes to the fire protection program, in accordance with License Condition 2.C(5), as described in the Updated Safety Analysis Report (USAR). The change requested a deviation from USAR Appendix 9.5E 10 CFR Part 50 Appendix R Comparison, to allow the use of portable lighting as the primary emergency lighting means (with limited exceptions) for illuminating safe shutdown equipment and access egress routes to the equipment. During the Nuclear Regulatory Commissions (NRC) review of the documentation, a discrepancy was identified in the operating license and USAR markup of the Reference.

Specifically, the operating license utilizes the abbreviation for number (No.) in the listing of Amendment number 189 whereas the current authority file only states Amendment 189.

Additionally, page 9.5-44 of section 9.5.3.3 of the USAR contains partially covered text and does not distinguish whether the text was intended for deletion.

To address these discrepancies, Attachment I to this letter provides the corrected operating license with the abbreviation of number in Amendment 189 removed. Attachment II to this letter provides the corrected USAR markup for page 9.5-44 with the requested changes clearly illustrated. Since the requested change does not utilize portable lighting for illuminating all safe shutdown equipment and access egress routes to the equipment, applicable portions of Section 9.5.3.3 of page 9.5-44 still apply. The supplement provided does not alter the conclusions reached in Attachment I of the Reference. In accordance with 10 CFR 50.91, Notice for public comment; State consultation, a copy of this letter, with attachments, is being provided to the designated Kansas State official.

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831

ET 23-000048 Page 2 of 3 This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-8831 x8687, or Dustin Hamman at (620) 364-4204.

Sincerely, Lance Lane, Acting VP Engineering Michael T. Boyce MTB/

Attachments: I Corrected Markup of the Renewed Facility Operating License II Corrected Markup of USAR Page 9.5-44 cc: S. S. Lee (NRC), w/a J. D. Monninger, (NRC), w/a G. E. Werner (NRC), w/a Senior Resident Inspector (NRC), w/a J. Meinholdt (KDHE), w/a WC Licensing Correspondence, w/a - ET 23-000048

ET 23-000048 Page 3 of 3 STATE OF KANSAS )

) ss COUNTY OF COFFEY )

Lance Lane, of lawful age, being first duly sworn upon oath says that he is Acting Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the 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~ Lori~ L~

Lance Lane I

Acting Vice President Engineering SUBSCRIBED and sworn to before me this t day of ~~~ , 2023.

JENA MICHELLE STUCKER Motary Public

• Sta~e of ~a~~

My Appointment E:xp1res ...:i~....,\u.-- Expiration Date _ _.... \ -----'1.Jfl"'--_-'1_

\_-....\ ....

Attachment I to ET 23-000048 Page 1 of 2 Corrected Markup of the Renewed Facility Operating License

Attachment I to ET 23-000048 5 Page 2 of 2 (5) Fire Protection (Section 9.5.1, SER, Section 9.5.1.8, SSER #5)

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment 189, Amendment No. 191, Amendment No. 193, Amendment No. 205, and Amendment No. XXX, and Amendment No. 214, subject to provisions b and c below.

(b) The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(c) Deleted.

(6) Qualification of Personnel (Section 13.1.2, SSER #5, Section 18, SSER

1. 1)

Deleted per Amendment No. 141.

(7) NUREG-0737 Supplement 1 Conditions (Section 22, SER)

Deleted per Amendment No. 141.

(8) Post-Fuel-Loading Initial Test Program (Section 14, SER Section 14, SSER #5)

Deleted per Amendment No. 141.

(9) Inservice Inspection Program (Sections 5.2.4 and 6.6, SER)

Deleted per Amendment No. 141.

(10) Emergency Planning Deleted per Amendment No. 141.

(11) Steam Generator Tube Rupture (Section 15.4.4, SSER #5)

Deleted per Amendment No. 141.

(12) LOCA Reanalysis (Section 15.3.7, SSER #5)

Deleted per Amendment No. 141.

Renewed License No. NPF-42

Attachment II to ET 23-000048 Page 1 of 2 Corrected Markup of USAR Page 9.5-44

Attachment II to ET 23-000048 Page 2 of 2 WOLF CREEK For cold shutdown, operator actions may be required in the electrical penetration rooms (1409 and 1410) to isolate the accumulator tanks and to open the RHR suction valves from the hot legs. These actions may be taken as late as 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an event. The safe shutdown scenario does not require access to the containment for hot shutdown but could require access to containment for cold shutdown.

The 8-hour battery-backed emergency lighting fixtures provide lighting for fire fighting activities in the areas listed previously. For fires in the general plant areas, operator actions may be required outside of the control room to maintain hot standby. In the event of a fire, the standby lighting system should remain operable; however, the emergency lighting provides access to the areas and lighting within the areas where operator actions are required. These provisions meet the requirements of 10 CFR 50, Appendix R, Paragraph III.J.

In areas required to be manned for safe shutdown, sufficient lighting is directed at the control panels to enable operation of controls. This includes the following:

a. Main control board with 8-hour

b. Auxiliary shutdown panel(s) battery packs

c. Diesel generator control panel(s)

In the area above the main control board and operator's console, the emergency lighting system consists of emergency lights with 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery packs and fixtures supplied from a Class IE battery through a normally deenergized contactor. The contactor control circuit monitors the normal ac lighting feed and automatically energizes the fixtures from one Class IE battery upon loss of ac power. The contactor, switch, wiring, raceways, and fixture mounting for this system are equivalent to Class IE with regard to separation, color coding, and seismic supports.

One and one-half hour battery units are used in the turbine building and the hot machine shop. Each unit is connected to the normal lighting ac source for maintaining the charge and is automatically transferred to its internal batteries upon loss of ac power.

battery 9.5.3.3 Failure Analysis The emergency lighting system is designed to provide lighting in areas used during safe-shutdown, design basis events or fire fighting activities. In the event of loss of offsite power, the emergency lighting is maintained by batteries, as outlined in Section 9.5.3.2.3. The standby lighting system in these areas is powered from the emergency diesel generators in the event of the loss of offsite power. Refer to Section 9.5.3.2.2.

The emergency lighting strategy involves a diverse approach utilizing the following:

• 8-hour fixed battery units for the locations that may require long term attendance in support of safe shutdown. These locations are identified in E-1F9900.

Remaining fixed emergency

• Portable (hard hat mounted) lighting for illuminating lighting units for the implementing procedures, safe shutdown equipment, and the access powerblock have 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> egress routes to the equipment. This will be the primary battery capacity, which emergency lighting method for most locations.

provides illumination for fire fighting activities,

• 1.5-hour fixed battery units for firefighting activities, life safety access/egress, life safety access/egress, and supplementary lighting to portable and supplemental lighting to lighting.

portable lighting.

9.5-44 Rev. 27