ML26076A441

License Amendment Request to Adopt TSTF-427-A, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability

ML26076A441
Person / Time
Site:	Wolf Creek
Issue date:	03/17/2026
From:	Bayer R Wolf Creek
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
001402
Download: ML26076A441 (0)

Text

Robert J. Bayer Vice President Engineering March 17, 2026 001402 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket No. 50-482: License Amendment Request to Adopt TSTF-427-A, Revision 2, "Allowance for Non Technical Specification Barrier Degradation on Supported System Operability" Commissioners and Staff:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR 50.90), Wolf Creek Nuclear Operating Corporation (WCNOC) is submitting a request for an amendment to the Technical Specifications (TS) for Wolf Creek Generating Station (WCGS).

The proposed amendment would modify TS requirements for unavailable barriers by adding Limiting Condition for Operation (LCO) 3.0.9. The proposed changes are consistent with Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-427-A, Revision 2, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," dated May 3, 2006.

Included with this license amendment request are the following attachments.

Attachment I provides a description of the proposed change and confirms its applicability.

Attachment II includes the existing WCGS TS pages marked up to show the proposed changes.

Attachment III provides the clean, formatted WCGS TS pages incorporating the proposed changes.

Attachment IV contains the existing WCGS TS Bases pages marked up to show the proposed changes. Changes to the TS Bases are provided for information only and will be implemented under the TS Bases Control Program.

Attachment V provides a summary of proposed regulatory commitments made in this submittal.

WCNOC requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLllP). Per the process, approval of the proposed amendment is requested within six months of completion of the NRC's acceptance review. Once approved, the amendment shall be implemented within 120 days.

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

001402 Page 2 of 2 WCNOC has determined that this amendment application does not involve a significant hazards consideration as determined per 10 CFR 50.92, "Issuance of amendment." The amendment application was reviewed by the WCNOC Plant Safety Review Committee. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," section (b)(1), a copy of this application, with attachments, is being provided to the designated Kansas State official.

As noted above, Attachment V provides a summary of proposed regulatory commitments made in this submittal. If you have any questions regarding this matter, please contact me at (620) 364-4015 or Dustin Hamman at (620) 364-4204.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 17th day of March 2026.

Sincerely, Robert J. Bayer RJB/nwl Attachments:

I Description and Assessment II Proposed Technical Specification Mark-ups III Proposed Technical Specification Clean Pages IV Proposed Technical Specification Bases Mark-ups (Information Only)

V Summary of Commitments cc:

A. N. Agrawal (NRC), w/a S. S. Lee (NRC), w/a J. Meinholdt (KDHE), w/a J. D. Monninger (NRC), w/a Senior Resident Inspector (NRC), w/a WCNOC Licensing Correspondence ET 26-001402, w/a

Attachment I to 001402 Page 1 of 4 Attachment I Description and Assessment

Subject:

License Amendment Request to Adopt TSTF-427-A, Revision 2, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY"

1. DESCRIPTION

2. ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Analysis 3.2 Verification and Commitments

4. ENVIRONMENTAL EVALUATION

5. REFERENCES

Attachment I to 001402 Page 2 of 4

1.0 DESCRIPTION

The proposed amendment would modify Wolf Creek Generating Station (WCGS) Technical Specification (TS) requirements for unavailable barriers by adding Limiting Condition for Operation (LCO) 3.0.9. The proposed changes are consistent with Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF) Standard Technical Specification change, TSTF-427-A, Revision 2, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," dated May 3, 2006 (Reference 1). The availability of this TS improvement was announced in the notice of availability published in the Federal Register on October 3, 2006 (Reference 2), as part of the Consolidated Line Item Improvement Process (CLllP).

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Wolf Creek Nuclear Operating Corporation (WCNOC) has reviewed the safety evaluation in the notice of availability published in the Federal Register (Reference 2), as part of the CLllP. This included a review of the NRC staff's evaluation, as well as information provided to support TSTF-427. WCNOC has concluded that the justifications presented in the TSTF-427 proposal and the corresponding NRC Safety Evaluation (SE) are applicable to WCGS and justify this amendment for the incorporation of the changes to the WCGS TS.

WCNOC reviewed the Probabilistic Risk Assessment (PRA) conclusions in the NRC SE. While the initiating event frequencies in the NRC SE do not in all cases bound the WCGS PRA initiating event frequencies, a WCGS-specific analysis was developed using the NRCs process, and the results indicate that WCGSs risk for a 30-day barrier unavailability falls in the very low risk category of Regulatory Guide (RG) 1.174. Therefore, the NRC's generic risk conclusions are applicable to WCGS.

2.2 Optional Changes and Variations WCNOC is not proposing any variations or deviations from the TS changes described in TSTF-427, Revision 2, or the NRC model safety evaluation dated October 3, 2006.

The mark-up of the TS Bases associated with LCO 3.0.9 as presented in TSTF-427, is included in Attachment IV for information purposes. The LCO 3.0.9 Bases in TSTF-427 indicate that risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide (RG) 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

In the Federal Register dated November 27, 2012 (77 FR 70846), the NRC provided notice that RG 1.182 had been withdrawn and the subject matter had been incorporated into RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The TSTF issued a letter (Reference

3) noting which approved TSTF travelers are affected and described the effect of withdrawal of RG 1.182. An NRC letter (Reference 4) endorsed the TSTF's approach in the handling of future license amendment requests. As such, WCNOC is referencing RG 1.160 in the TS Bases associated with this amendment request.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

Attachment I to 001402 Page 3 of 4 Wolf Creek Nuclear Operating Corporation (WCNOC) has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLllP. WCNOC has concluded that the proposed NSHCD, presented in the notice of availability published in the Federal Register (Reference 2), is applicable to WCGS and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a), "Notice for public comment."

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register (Reference 2) for this TS improvement, plant-specific verifications will be performed as follows.

1. WCNOC commits to following the guidance in Section 11 of NUMARC 93-01 (Reference 5),

for situations in which a barrier is considered unavailable and the requirements of LCO 3.0.9 are applied, to assess and manage risk during maintenance.

2. WCNOC will revise procedures to ensure that the risk assessment and management process described in Nuclear Energy Institute (NEI) 04-08 (Reference 6) is used whenever a barrier is considered unavailable and the requirements of LCO 3.0.9 are to be applied, in accordance with an overall configuration risk management program to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified and avoided.

4.0 ENVIRONMENTAL EVALUATION WCNOC has reviewed the environmental evaluation included in the model safety evaluation dated October 3, 2006, as part of the CLllP. WCNOC has concluded that the staff's findings presented in that evaluation are applicable to WCGS and the evaluation is hereby incorporated by reference for this application.

5.0 REFERENCES

1. TSTF-427-A, Revision 2, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," dated May 3, 2006 (ML061240055)

2. Federal Register, Vol. 71, p. 58444, dated October 3, 2006, Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding the Addition of LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process.

3. Letter from the Technical Specifications Task Force to U.S. Nuclear Regulatory Commission, "Revision of References to Regulatory Guide 1.182 in Approved Travelers," TSTF-14-10, dated September 16, 2014 (ML14259A575)

4. Letter from A. Mendiola (U.S. Nuclear Regulatory Commission) to Technical Specifications Task Force (TSTF), "U.S. Nuclear Regulatory Commission Response to the TSTF Letter Regarding References to Regulatory Guide 1.182 in Approved Travelers," dated February 26, 2015 (ML15033A152)

5. NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants"

Attachment I to 001402 Page 4 of 4

6. NEI 04-08, "Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY (TSTF-427) Industry Implementation Guidance," dated March 2006 (ML061220426)

ATTACHMENT II Proposed Technical Specification Mark-ups Attachment II to 001402 Page 1 of 3

LCO Applicability 3.0 Wolf Creek - Unit 1 3.0-1 Amendment No. 123, 155, 173 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />; b.

MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and c.

MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other (continued)

Attachment II to 001402 Page 2 of 3

LCO Applicability 3.0 Wolf Creek - Unit 1 3.0-3 Amendment No. 173 3.0 LCO Applicability LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a.

the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or b.

the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

LCO 3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

Attachment II to 001402 Page 3 of 3

ATTACHMENT III Proposed Technical Specification Clean Pages (3 Pages)

Attachment III to 001402

LCO Applicability 3.0 Wolf Creek - Unit 1 3.0-1 Amendment No. 123, 155, 173 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;

b.

MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and

c.

MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other (continued)

LCO Applicability 3.0 Wolf Creek - Unit 1 3.0-3 Amendment No. 173 3.0 LCO Applicability LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a.

the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or

b.

the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

LCO 3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

ATTACHMENT IV Proposed Technical Specification Bases Mark-ups (Information Only)

Attachment IV to 001402 Page 1 of 5

LCO Applicability B 3.0 Wolf Creek - Unit 1 B 3.0-1 Revision 81 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILTY BASES LCOs LCO 3.0.1 through LCO 3.0.89 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified.

The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a.

Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and b.

Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Attachment IV to 001402 Page 2 of 5

LCO Applicability B 3.0 Wolf Creek - Unit 1 B 3.0-11 Revision 81 BASES LCO 3.0.8 LCO 3.0.8.b applies when one or more snubbers are not capable of (continued) providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

LCO 3.0.9 LCO 3.0.9 establishes conditions under which systems described in the Technical Specifications are considered to remain OPERABLE when required barriers are not capable of providing their related support function(s).

Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical Specifications, that support the performance of the safety function of systems described in the Technical Specifications. This LCO states that the supported system is not considered to be inoperable solely due to required barriers not capable of performing their related support function(s) under the described conditions. LCO 3.0.9 allows 30 days before declaring the supported system(s) inoperable and the LCO(s) associated with the supported system(s) not met. A maximum time is placed on each use of this allowance to ensure that as required barriers are found or are otherwise made unavailable, they are restored.

However, the allowable duration may be less than the specified maximum time based on the risk assessment.

If the allowed time expires and the barriers are unable to perform their related support function(s), the supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

Attachment IV to 001402 Page 3 of 5

LCO Applicability B 3.0 Wolf Creek - Unit 1 B 3.0-12 Revision 81 LCO 3.0.9 This provision does not apply to barriers which support ventilation (continued) systems or to fire barriers. The Technical Specifications for ventilation systems provide specific Conditions for inoperable barriers. Fire barriers are addressed by other regulatory requirements and associated plant programs. This provision does not apply to barriers which are not required to support system OPERABILITY (see NRC Regulatory Issue Summary 2001-09, "Control of Hazard Barriers," dated April 2, 2001).

The provisions of LCO 3.0.9 are justified because of the low risk associated with required barriers not being capable of performing their related support function. This provision is based on consideration of the following initiating event categories:

Loss of coolant accidents;

High energy line breaks;

Feedwater line breaks;

Internal flooding;

External flooding;

Turbine missile ejection; and

Tornado or high wind.

The risk impact of the barriers which cannot perform their related support function(s) must be addressed pursuant to the risk assessment and management provision of the Maintenance Rule, 10 CFR 50.65 (a)(4),

and the associated implementation guidance, Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This guidance provides for the consideration of dynamic plant configuration issues, emergent conditions, and other aspects pertinent to plant operation with the barriers unable to perform their related support function(s). These considerations may result in risk management and other compensatory actions being required during the period that barriers are unable to perform their related support function(s).

LCO 3.0.9 may be applied to one or more trains or subsystems of a system supported by barriers that cannot provide their related support function(s), provided that risk is assessed and managed (including consideration of the effects on Large Early Release and from external events). If applied concurrently to more than one train or subsystem of a multiple train or subsystem supported system, the barriers supporting each of these trains or subsystems must provide their related support function(s) for different categories of initiating events. For example, LCO 3.0.9 may be applied for up to 30 days for more than one train of a multiple train supported system if the affected barrier for one train protects against internal flooding and the affected barrier for the other train protects against tornado missiles. In this example, the affected Attachment IV to 001402 Page 4 of 5

LCO Applicability B 3.0 Wolf Creek - Unit 1 B 3.0-13 Revision 81 LCO 3.0.9 barrier may be the same physical barrier but serve different protection (continued) functions for each train.

If during the time that LCO 3.0.9 is being used, the required OPERABLE train or subsystem becomes inoperable, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, the train(s) or subsystem(s) supported by barriers that cannot perform their related support function(s) must be declared inoperable and the associated LCOs declared not met. This 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period provides time to respond to emergent conditions that would otherwise likely lead to entry into LCO 3.0.3 and a rapid plant shutdown, which is not justified given the low probability of an initiating event which would require the barrier(s) not capable of performing their related support function(s). During this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the plant risk associated with the existing conditions is assessed and managed in accordance with 10 CFR 50.65(a)(4).

Attachment IV to 001402 Page 5 of 5

ATTACHMENT V Summary of Commitments Attachment V to 001402 Page 1 of 2

Attachment V Summary of Commitments The following table identifies the regulatory commitments made in this document. All other statements in this submittal describe intended or planned actions and are provided for information only; they do not constitute regulatory commitments.

Commitment Committed Date or "Outage" Commitment Type One-Time Action (Yes/No)

Programmatic (Yes/No)

1. WCNOC commits to following the guidance in Section 11 of NUMARC 93-01, for situations in which a barrier is considered unavailable and the requirements of LCO 3.0.9 are applied, to assess and manage risk during maintenance.

120 days following NRC approval No Yes

2. WCNOC will revise procedures to ensure that the risk assessment and management process described in NEI 04-08 is used whenever a barrier is considered unavailable and the requirements of LCO 3.0.9 are to be applied, in accordance with an overall configuration risk management program to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified and avoided.

120 days following NRC approval No Yes Attachment V to 001402 Page 2 of 2