ML23289A261
| ML23289A261 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/16/2023 |
| From: | Boyce M Wolf Creek |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 000147 | |
| Download: ML23289A261 (1) | |
Text
P.O. Box 411 l Burlington, KS 66839 l 620-364-8831 Michael T. Boyce Vice President Engineering October 16, 2023 000147 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Reference:
Letter ET 23-0003 dated March 1, 2023, from M. T. Boyce, WCNOC, to USNRC, License Amendment Request (LAR) for Removal of the Power Range Neutron Flux Rate - High Negative Rate Trip Function from Technical Specifications (ML23060A481)
Subject:
Docket No. 50-482: Supplement to License Amendment Request (LAR) for Removal of the Power Range Neutron Flux Rate - High Negative Rate Trip Function from Technical Specifications Commissioners and Staff:
This letter is a supplement to the Reference in which Wolf Creek Nuclear Operating Corporation (WCNOC) submitted an application, pursuant to 10 CFR 50.90, requesting removal of the Power Range Neutron Flux Rate - High Negative Rate Trip Function from the Technical Specifications (TS). During the Nuclear Regulatory Commissions (NRC) review of the documentation, a question was raised as to whether or not WCNOC was requesting approval from the NRC to make the changes provided for the Updated Safety Analysis Report (USAR) mark-ups in the Reference.
To address this question, Attachment I to this letter provides a revision to the information contained in section 2.4 of page 3 for the evaluation of proposed change contained in Attachment I of the Reference. The revision corrects the language utilized to clearly indicate that the USAR provided mark-ups are intended for information use only and will be formally implemented through Wolf Creek Generating Stations (WCGS) 10 CFR 50.59 process. The revision also indicates that the information provided will only be changed following approval of the proposed TS changes by the NRC. The revision only alters the information on page 3 and does not impact any information contained on the remaining pages. Additionally, Attachment II to this letter provides a revised cover page for Attachment III of the Reference. The revised cover page provides additional clarification that the provided mark-ups for the USAR are intended for information use only.
The additional information provided in the supplement 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.
W o If C re e k...rw~,~J'TJ'>
Nuclear Operating Corporation
ET 23-00014 7 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, Michael T. Boyce MTB/
Attachments: I II Revised Section 2.4 for Attachment I (Page 3) of Letter ET 23-0003 Revised Cover Page for Attachment Ill (Page 1) of Letter ET 23-0003 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, wo/a - ET 23-000147 nwl
ET 23-000147 Page 3 of 3 STATE OF KANSAS
)
) 55 COUNTY OF COFFEY )
Michael T. Boyce, of lawful age, being first duly sworn upon oath says that he is 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.
8~ict::ftzr Vice President Engineering SUBSCRIBED and sworn to before me this I lQ day of
<() ~"'DQ.%
I 2023, taPublic JENA MICHELLE STUCKER Notary Public
- State of Kan\\~1')
My Appointment Expires -1..,\\-=--'---
Expiration Date _--4-}-_l1_-_'l_D_'2_1_
Attachment I to ET 23-000147 Revised Section 2.4 for Attachment I (Page 3) of Letter ET 23-0003
Attachment I to ET 23-0003 Page 3 of 8 the design Departure from Nucleate Boiling Ratio (DNBR) limits continue to be met with the new Rod Cluster Control Assembly (RCCA) methodology; independent of the Power Range Neutron Flux Rate - High Negative Rate Trip function. Thus, the proposed change in this amendment request would delete an unnecessary trip function which, in turn, would avoid unnecessary reactor trip initiating events.
2.4 Description of the Proposed Change The proposed change would delete the TS requirement for the Power Range Neutron Flux Rate
- High Negative Rate Trip function. This function, as specified in Table 3.3.1-1, Reactor Trip System Instrumentation, of the TS as Function 3.b, Power Range Neutron Flux Rate - High Negative Rate, would be deleted. The specific changes to Table 3.3.1-1 (i.e., the mark-up of the proposed change) are contained in Attachment II.
Currently, TS 3.3.1 requires that the Power Range Neutron Flux Rate - High Negative Rate Trip Function have four (4) of the channels operable while in MODES 1 and 2. Following application of the proposed change, the Power Range Neutron Flux Rate - High Negative Rate Trip Function would be deleted, meaning that the trip function would not be required for operation in any MODE.
Deletion of the High Negative Rate trip function from Table 3.3.1-1 would leave the High Positive Rate trip function as the only function for the Power Range Neutron Flux Rate Instrumentation.
The proposed change would remove the a listing for the High Positive Rate and relocate the associated description of the function to make a single row. This change seeks to simplify Table 3.3.1-1 following the removal of the High Negative Rate trip function and does not alter any of the descriptions associated with the High Positive Rate Function.
Additionally, the Updated Safety Analysis Report (USAR) mark-ups associated with the proposed change for Section 7.2 (Pages 5, 41, 46, and 49) and Section 15 Table 15.0-6 (Sheet 3, Page 32) are provided for information use only. The specific changes to the USAR are detailed in Attachment III. Section 7.2 of the USAR describes the RTS as configured at the WCGS, including the system description as well as the various trip functions. Currently, Section 7.2 describes the Power Range Neutron Flux Rate - High Negative Rate Trip function in its current configuration and the response given a sudden abnormal decrease in nuclear power. Table 15.0-6 of the USAR (Sheet 3) describes the reactor trip function response for an incident of RCCA mis-alignment. A response to the incident is the RTS Power Range Negative Flux Rate trip function. Following application of the proposed change, the descriptions of the Power Range Neutron Flux Rate -
High Negative Rate Trip function in the aforementioned sections would be deleted and replaced with a statement indicating the functions removal per the License Amendment. Section 7.2 (Page
- 5) also relocates a description contained in the High Negative Rate trip function description to the description for the High Positive Rate trip function. The statement relocated is generic and does not specifically apply to the High Negative trip function. The associated changes to the USAR will be made following approval of the proposed TS change via the WCGS 10 CFR 50.59 process.
The proposed changes would revise Paragraph 2.C.(2) of the renewed facility operating license as a result of the new amendment received, should the proposed changes be approved. The new amendment number received will also be reflected in the applicable sections of the TS for which the amendment applies. The mark-up of the renewed facility operating license accounting for this is provided in Attachment IV.
Lastly, changes to the existing TS Bases are provided in Attachment V for information only. The removal of the Power Range Neutron Flux - High Negative Rate trip function is reflected in the markups. In a similar manner to the TS, the a listing for the High Positive Rate trip function will be removed as the function is the only Power Range Neutron Flux Rate trip function. The changes
Attachment II to ET 23-000147 Revised Cover Page for Attachment III (Page 1) of Letter ET 23-0003
Attachment III to ET 23-0003 Page 1 of 6 Proposed USAR Changes (Mark-up) for Information Use Only