ML24199A171

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Issuance of Amendment No. 241 Revise Ventilation Filter Testing Program Criteria and Administrative Correction of Absorber in Technical Specification 5.5.11
ML24199A171
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 09/17/2024
From: Samson Lee
NRC/NRR/DORL/LPL4
To: Reasoner C
Wolf Creek
References
EPID L-2023-LLA-0164
Download: ML24199A171 (1)


Text

September 17, 2024 Cleveland Reasoner Chief Executive Officer and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION, UNIT 1 - ISSUANCE OF AMENDMENT NO. 241 RE: REVISE VENTILATION FILTER TESTING PROGRAM CRITERIA AND ADMINISTRATIVE CORRECTION IN TECHNICAL SPECIFICATION 5.5.11 (EPID L-2023-LLA-0164)

Dear Cleveland Reasoner:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 241 to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station, Unit 1. The amendment consists of changes to the technical specifications (TSs) in response to your application dated November 16, 2023.

The amendment revises the ventilation filter testing program criteria in TS 5.5.11.b and corrects an administrative error of the word absorber in TS 5.5.11, Ventilation Filter Testing Program (VFTP).

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Samson S. Lee, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosures:

1. Amendment No. 241 to NPF-42
2. Safety Evaluation cc: Listserv WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION, UNIT 1 DOCKET NO. 50-482 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 241 License No. NPF-42 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment to the Wolf Creek Generating Station, Unit 1 (the facility) Renewed Facility Operating License No. NPF-42 filed by the Wolf Creek Nuclear Operating Corporation (the Corporation), dated November 16, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-42 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 241, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.

229, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

The license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Jennivine K. Rankin, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: September 17, 2024 Jennivine K. Rankin Digitally signed by Jennivine K.

Rankin Date: 2024.09.17 06:02:38 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 241 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK GENERATING STATION, UNIT 1 DOCKET NO. 50-482 Replace the following pages of Renewed Facility Operating License No. NPF-42 and the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT 4

4 Technical Specifications REMOVE INSERT 5.0-15 5.0-15 5.0-16 5.0-16

4 (5)

The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6)

The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The Operating Corporation is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100%

power) in accordance with the conditions specified herein.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 241, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 229, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Antitrust Conditions Evergy Kansas South, Inc. and Evergy Metro, Inc. shall comply with the antitrust conditions delineated in Appendix C to this license.

(4)

Environmental Qualification (Section 3.11, SSER #4, Section 3.11, SSER #5)*

Deleted per Amendment No. 141.

  • The parenthetical notation following the title of many license conditions denotes the section of the supporting Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-42 Amendment No. 241

Programs and Manuals 5.5 Wolf Creek - Unit 1 5.0-15 Amendment No. 123, 131, 139, 164, 241 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program (VFTP) (continued)

b.

Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < 1% when tested in accordance with Regulatory Guide 1.52, Revision 2 at the system flowrate specified below +/- 10%.

ESF Ventilation System Flowrate Control Room Emergency Ventilation System - Filtration 2000 cfm Control Room Emergency Ventilation System-Pressurization 750 cfm Auxiliary/Fuel Building Emergency Exhaust 6500 cfm

c.

Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration RH Control Room Emergency Ventilation System (Filtration/Pressurization) 2.5%

70%

Auxiliary/Fuel Building Emergency Exhaust 5%

70%

d.

Demonstrate at least once per 18 months for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, at the system flowrate specified below +/- 10%.

ESF Ventilation System Delta P Flowrate Control Room Emergency Ventilation System - Filtration 6.6 in. W.G. 2000 cfm Control Room Emergency Ventilation System - Pressurization 3.6 in. W.G. 750 cfm Auxiliary/Fuel Building Emergency Exhaust 4.7 in. W.G. 6500 cfm (continued)

Programs and Manuals 5.5 Wolf Creek - Unit 1 5.0-16 Amendment No. 123, 131, 164, 241 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program (VFTP) (continued)

e.

Demonstrate at least once per 18 months that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1975.

ESF Ventilation System Wattage Control Room Emergency Ventilation System - Pressurization 5 +/- 1 kW Auxiliary/Fuel Building Emergency Exhaust 37 +/- 3 kW

f.

Demonstrate at least once per 18 months for each of the ESF systems that following the creation of an artificial Delta P across the combined HEPA filters, the prefilters, and the charcoal adsorbers of not less than the value specified below (dirty filter conditions), that the flowrate through these flow paths is with +/- 10% of the value specified below when tested in accordance with ANSI N510-1980.

ESF Ventilation System Delta P Flowrate Control Room Filtration System 6.6 in. W.G.

2000 cfm Control Room Pressurization System 3.6 in. W.G.

750 cfm Auxiliary/Fuel Building Emergency Exhaust 4.7 in. W.G.

6500 cfm The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, Revision 0, July 1981, "Postulated Radioactive Release due to Waste Gas System Leak or Failure." The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Revision 2, July 1981, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures."

(continued)

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 241 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION, UNIT 1 DOCKET NO. 50-482

1.0 INTRODUCTION

By letter dated November 16, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23320A277), Wolf Creek Nuclear Operating Corporation (the licensee) submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) for an amendment to the technical specifications (TSs) for the Wolf Creek Generating Station, Unit 1 (Wolf Creek) Renewed Facility Operating License No. NPF-42.

The proposed amendment would change TS 5.5.11.b within TS 5.5.11, Ventilation Filter Testing Program (VFTP), by changing the testing requirements for the in-place test of the charcoal adsorber penetration and system bypass from less than 0.05 percent to less than 1 percent. The requested change is based on the charcoal adsorber efficiency assumed in Wolf Creeks safety analysis, as approved by the NRC in Amendment No. 221, dated May 31, 2019 (ML19100A122), and has no impact on the frequency at which the testing occurs. Additionally, the LAR proposed to replace all references of the term absorber in TSs 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f with the term adsorber.

2.0 REGULATORY EVALUATION

2.1 Regulatory Requirements The NRC regulatory requirements related to the content of the TSs are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications. As required by 10 CFR 50.36(c)(3), TSs will include surveillance requirements, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The regulation in 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, states, in part, that [w]henever a holder of a license desires to amend the license or permit, application for an amendment must be filed with the Commission.

Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants, General Design Criterion (GDC) 19, Control room, states, in part, that, A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.

Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem [roentgen equivalent man] whole body, or its equivalent to any part of the body, for the duration of the accident. Equipment at appropriate locations outside the control room shall be provided.

(1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.

Appendix A to 10 CFR Part 50, GDC 61, Fuel storage and handling and radioactivity control, states that, The fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection, (3) with appropriate containment, confinement, and filtering systems, (4) with a residual heat removal capability having reliability and testability that reflects the importance to safety of decay heat and other residual heat removal, and (5) to prevent significant reduction in fuel storage coolant inventory under accident conditions.

2.2 Regulatory Guidance Regulatory Guide (RG) 1.52, Revision 2, Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, March 1978 (ML003740139), provides guidance for design, testing, and maintenance criteria for post-accident engineered safety feature (ESF) cleanup system air filtration and adsorption units of light-water-cooled nuclear power plants.

Generic Letter (GL) 83-13, Clarification of Surveillance Requirements for HEPA [High Efficiency Particulate Air] Filters and Charcoal Adsorber Units in Standard Technical Specifications on ESF Cleanup Systems, March 2, 1983 (ML031080366), provides clarification of surveillance requirements for HEPA filters and charcoal adsorber units in standard technical specifications on ESF cleanup systems.

3.0 TECHNICAL EVALUATION

3.1 System Description and Operation In section 2.1, System Design and Operation, of attachment I, Evaluation of Proposed Change, to the LAR, the licensee states:

The safety-related filtration units containing charcoal adsorbers are located in the fuel building and control building. For the control building, the Control Room Emergency Ventilation System (CREVS) provides a protected, controlled temperature environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. CREVS consists of two independent, redundant trains that recirculate, cool, pressurize, and filter the air in the control room envelope (CRE) and control building envelope (CBE) that limits the in-leakage of unfiltered air. Each CREVS train consists of a recirculation system train and a pressurization train. The filtration portion of each system consists of a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA follows the adsorber section to collect carbon fines.

Each pressurization system train consists of ductwork to bring air from outside the building, a moisture separator, an electric heater, a HEPA, an activated charcoal adsorber, and a second HEPA. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system.

The CREVS is an emergency system which may also operate during normal unit operations. Upon receipt of the actuating signal, normal air supply and exhaust to the CRE is isolated, and a portion of the ventilation air is recirculated through the filtration system train(s), and the pressurization system is started. The filtration system prefilters remove any large particles in the air, and the pressurization system moisture separator removes any entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers. Actuation of the CREVS by a Control Room Ventilation Isolation Signal (CRVIS), places the system in the emergency mode of operation. Actuation of the system in emergency mode of operation closes the unfiltered outside air intake and unfiltered exhaust dampers and aligns the system for recirculation. A portion of the recirculation of the air within the CRE flows through the redundant filtration systems trains of HEPA and the charcoal adsorbers. The CRVIS also initiates pressurization and filtered ventilation of the air supply to the CRE.

The Emergency Exhaust System serves both the auxiliary building and fuel building. Following a loss of coolant accident (LOCA), safety related dampers isolate the auxiliary building, and the Emergency Exhaust System exhausts potentially contaminated air from the Emergency Core Cooling System areas and from the Hydrogen Purge System. The Emergency Exhaust System filters airborne radioactive particulates from the area of the fuel pool following a fuel

handling accident. Following a LOCA, the system is aligned to the auxiliary building; however, a limited amount of air from the fuel building is processed through the Emergency Exhaust System to prevent excessive negative pressure in the auxiliary building.

The Emergency Exhaust System consists of two independent and redundant trains. Each train consists of a heater, a prefilter, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines),

and a fan. Ductwork, dampers, and instrumentation also form part of the system, as well as heaters, functioning to reduce the relative humidity of the airstream.

The system initiates filtered ventilation of the fuel building following receipt of a fuel building isolation signal. The Emergency Exhaust System is on standby for an automatic start following receipt of a fuel building ventilation isolation signal (FBVIS) or a safety injection signal (SIS). Initiation of the LOCA (SIS) mode of operation takes precedence over any other mode of operation. In the LOCA mode the system is aligned to exhaust the auxiliary building. Upon receipt of a fuel building ventilation isolation signal generated by gaseous radioactivity monitors in the fuel building exhaust line, normal air discharges from the building are terminated, the fuel building is isolated, and the stream of ventilation air discharges through the system filter trains.

The charcoal adsorbers are qualified in accordance with Regulatory Guide 1.52, Revision 2, and are factory tested in accordance with RDT M-16-IT to exhibit a decontamination efficiency of no less than 99.9% for elemental iodine and 98%

for methyl iodide. Sample charcoal canisters are tested for impregnant efficiency in an independent laboratory, using radiomethyl iodide tracers. In-place testing is performed with a suitable refrigerant, in accordance with procedures set forth in ANSI [American National Standards Institute] N510, to check for bed bypass leakages.

3.2 Proposed Changes The licensee proposed to change TS 5.5.11 within the ventilation filter testing program. The proposed change would increase the acceptance criteria for the in-place test of the charcoal adsorber penetration and system bypass specified in TS 5.5.11.b from less than 0.05 percent to less than 1 percent. In addition, the licensee proposed a terminology correction to change the word absorber to adsorber in TSs 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f. These proposed changes would have no impact on the frequency at which the testing occurs.

3.2.1 Proposed TS Changes The licensee proposed the following changes to the TSs, deletions shown in strikethrough and additions shown in bold:

A portion of TS 5.5.11.b, which states:

Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorberabsorber shows a penetration and system bypass < 0.051% when tested in accordance with Regulatory Guide 1.52, Revision 2 at the system flowrate specified below +/- 10%.

Terminology in TS 5.5.11.c, TS 5.5.11.d, and TS 5.5.11.f: Each of these TSs contains a single occurrence of the terminology charcoal absorber or charcoal absorbers. The licensee proposed to change the terminology to charcoal absorberadsorber or charcoal absorbersadsorbers, respectively.

3.2.2 Reason for Proposed Changes ESF cleanup systems consist of HEPA and charcoal adsorber units. The periodic surveillance tests of charcoal adsorbers in TS 5.5.11 are the in-place penetration and bypass tests, and laboratory tests. The in-place tests are conducted at the nuclear facility, whereas the laboratory tests are conducted at a testing facility. Section 2.3 of attachment I to the LAR provided the reasons for the proposed changes, supplemented by the licensees technical evaluation contained in section 3 of attachment I to the LAR. The current in-place test of the charcoal adsorber in TS 5.5.11.b requires a penetration and system bypass of less than 0.05 percent when tested in accordance with RG 1.52, Revision 2. This essentially equates to 99.95 percent of halogenated hydrocarbon removal, the test medium during the in-place tests. The requirement between the in-place test and the charcoal adsorber efficiency were clarified in GL 83-13. Based on the clarifications, at the current bypass value of less than 0.05 percent, the charcoal adsorber efficiency of up to 99 percent is acceptable for the in-place tests, and at a higher bypass value of 1 percent, an adsorber efficiency of 95 percent or less is acceptable. In sections 2.3 and 3 of attachment I to the LAR, the licensee indicated that the analyses performed in its adoption of the alternative source term (AST), which was approved by the NRC in License Amendment No. 221, support a higher bypass value of less than 1 percent and that the current bypass value of less than 0.05 percent for the in-place tests is an undue burden that could lead to unnecessary system inoperability and maintenance.

The administrative change proposed for TS 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f revises the term absorber to adsorber as it is the more appropriate term to describe the function of the charcoal beds.

3.2.3 Evaluation of Proposed TS Changes 3.2.3.1 TS 5.5.11.b The methods presented in RG 1.52, Revision 2, regarding design, testing, and maintenance criteria for filtration and adsorption units apply to ESF atmosphere cleanup systems designed to mitigate the consequences of postulated accidents. TS 5.5.11.b applies to control room emergency ventilation system-filtration, control room emergency ventilation system-pressurization, auxiliary building emergency exhaust, and fuel building emergency exhaust, all of which are ESF atmosphere cleanup systems. The guidance in section C.5.d of RG 1.52, Revision 2, states, in part:

The activated carbon adsorber section should be leak tested with a gaseous halogenated hydrocarbon refrigerant in accordance with Section 12 of ANSI N510-1975 [Testing of Nuclear Air Cleaning Systems, American Society of Mechanical Engineers; Copies may be obtained from the American Society of Mechanical Engineers, United Engineering Center, 345 East 47th Street, New York, N.Y. 10017] to ensure that bypass leakage through the adsorber section is less than 0.05%.

Item 1.1 in the enclosure to GL 83-13 clarified that section C.5.d of RG 1.52, Revision 2, includes penetration and bypass leakage testing, not just bypass leakage testing.

The current TS 5.5.11.b aligns with this guidance by requiring that the charcoal adsorber show a penetration and system bypass of less than 0.05 percent.

The guidance in GL 83-13 provided further clarification to reflect the relationship between the guidance in RG 1.52, Revision 2, and ANSI N510-1975, resulting in the modification of the surveillance requirement associated with testing. GL 83-13 guidance provided the revised applicable values of the in-place penetration and bypass leakage testing acceptance criteria.

Specifically, it states, 0.05% value applicable when a HEPA filter or charcoal adsorber efficiency of 99% is assumed, or 1% when a HEPA filter or charcoal adsorber efficiency of 95%

or less is assumed in the NRC staffs safety evaluation.

By letter dated May 31, 2019, the NRC issued License Amendment No. 221 to Wolf Creek Renewed Facility Operating License No. NPF-42, approving the adoption of the AST radiological analysis methodology described in 10 CFR 50.67, Accident source term. The associated change was a full-scope implementation of the AST as described in RG 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000 (ML003716792). In section 3 of attachment I to the LAR, the licensee stated that the licensees AST analysis, as approved by the NRC in License Amendment No. 221, contained the following changes to the assumed charcoal adsorber efficiencies:

Table 4.3-5, Control Room and Control Building Parameters, illustrates that the filter efficiencies assumed for elemental iodine, organic iodine, and particulates are 95%.

Table 4.3-12, Assumptions Used for LOCA Analysis, illustrates that the auxiliary building exhaust filter efficiency (for all forms of iodine) is 90%.

Section 4.3.12.2.2 indicates that no credit is taken for filtration in the fuel building or containment for a fuel handling accident.

The NRC staff confirmed the above information in a review of the analysis contained in Enclosure IV, Full Scope Implementation of Alternate Source Term, Revision 1, November 2016 (ML17054C227), to the licensees AST submittal dated January 17, 2017 (package ML17054C103). Based on the clarifications presented in GL 83-13 that indicate less than 1 percent is acceptable for charcoal adsorber of less than 95 percent efficiency, and the design basis analysis performed for AST adoption, the proposed change to increase the charcoal adsorber in-place penetration and bypass from less than 0.05 percent to less than 1 percent is acceptable with a charcoal adsorber efficiency of 95 percent or less, as was assumed in the licensees AST analysis for License Amendment No. 221, which approved the AST adoption. The evaluation performed for the full scope implementation of AST used 95 percent filter efficiency for the control room ventilation system (filtration/pressurization) and 90 percent filter efficiency for the auxiliary building exhaust filter efficiency. The NRC staff notes that while the evaluations performed for the AST adoption assumed no credit for filtration in the fuel building or containment for a fuel handling accident, all the filtration systems in the current TS 5.5.11, including fuel building emergency exhaust, will remain in TS 5.5.11.b and will continue to be tested for 90 percent filter efficiency. Therefore, the NRC staff finds the proposed change to TS 5.5.11.b acceptable. The proposed terminology correction in TS 5.5.11.b from absorber to adsorber is addressed below.

3.2.3.2 TS 5.5.11.b, TS 5.5.11.c, TS 5.5.11.d, and TS 5.5.11.f The LAR states that the term adsorber was inadvertently changed to absorber when Wolf Creek transitioned to Improved Technical Specifications. The NRC staff concurs with the licensee that the term adsorber refers to a substance such as impregnated charcoal, which collects or adsorbs molecules or particles on its surface. The term adsorber is consistent with the terminology in the current and past revisions of NRC RG 1.52 and the American Society of Mechanical Engineers (ASME) AG-1, Code on Nuclear and Gas Treatment. The change is administrative only because it has no impact on the filter components or their filtration process.

Therefore, the NRC staff finds the nomenclature change acceptable.

3.2.4 Technical Conclusions The proposed change to TS 5.5.11.b increases the in-place test penetration and bypass of the charcoal adsorber from less than 0.05 percent to less than 1 percent. This results in a reduction of allowable charcoal adsorber efficiency from 99 percent to 95 percent or less. The radiological analysis evaluations resulting from this change were previously evaluated and approved by the NRC staff during Wolf Creek adoption of AST in License Amendment No. 221. The change does not involve, nor does it impact, any other aspects of the ESF filters. Therefore, the NRC staff finds the proposed change to TS 5.5.11.b acceptable and that the licensee will continue to meet 10 CFR 50.36(c)(3) and GDC 19 and 61. The NRC staff also finds the licensee will continue to conform to RG 1.52, Revision 2, as described in Appendix 3A of the Wolf Creek Updated Safety Analysis Report, Revision 37 (ML24114A124). The NRC staff also finds replacing all references of the term absorber in TSs 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f by the term adsorber acceptable. Therefore, the NRC staff finds the changes proposed in this LAR acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Kansas State official was notified of the proposed issuance of the amendment on July 3, 2024. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The amendment also changes a requirement with respect to recordkeeping, reporting, or administrative procedures or requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration as published in the Federal Register on January 23, 2024 (89 FR 4346), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Nageswara R. Karipineni, NRR Nicholas Soliz, NRR Joshua Wilson, NRR Sean Meighan, NRR Date: September 17, 2024

ML24199A171

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