WO 04-0042, Supplemental Information for Revision to Technical Specification 3.3.1, Reactor Trip System Instrumentation, and Technical Specification 3.3.2, Engineered Safety Feature Actuation System Instrumentation

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Supplemental Information for Revision to Technical Specification 3.3.1, Reactor Trip System Instrumentation, and Technical Specification 3.3.2, Engineered Safety Feature Actuation System Instrumentation
ML042880503
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 10/07/2004
From: Jacobs D
Wolf Creek
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
WO 04-0042
Download: ML042880503 (10)


Text

WALF CREEK

'NUCLEAR OPERATING CORPORATION Donna Jacobs Vice President Operations and Plant Manager October 7, 2004 WO 04-0042 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter WO 03-0059 dated December 15, 2003, from B. T. McKinney, WCNOC, to USNRC

Subject:

Docket No. 50-482: Supplemental Information for Revision to Technical Specification 3.3.1, 'Reactor Trip System Instrumentation," and Technical Specification 3.3.2, 'Engineered Safety Feature Actuation System Instrumentation" Gentlemen:

Reference 1 transmitted an application for amendment to Facility Operating License No. NPF-42 for the Wolf Creek Generating Station. The license amendment request propose changes to Technical Specification (TS) 3.3.1, "Reactor Trip System (RTS) Instrumentation," and TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," to adopt Completion Time, test bypass time, and Surveillance Frequency changes approved by the NRC in WCAP-14333-P-A, Revision 1, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times," October 1998 and WCAP-15376-P-A, Revision 1, "Risk-informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times," March 2003.

Reference 1 proposed to restructure TS 3.3.1 Condition D from what was approved in TSTF-418, Revision 2, to avoid confusion as to when a flux map for QUADRANT POWER TILT RATIO (QPTR) is required. Discussions with the NRC Project Manager and NRC Technical Specification Section personnel on July 13, 2004 and July 29, 2004 identified potential format concerns with the proposed Condition D. After further review, it was determined that the proposed Condition D should be further revised. The proposed revision was discussed with the NRC on July 29, 2004 and September 1, 2004.

Attachment I contains the proposed revision to Condition D and replaces pages 2 of 17 and 3 of 17 in Attachment II of Reference 1. Attachment II contains the revised TS Bases (for information only). This supplemental information does not impact the conclusions of the No Significant Hazards Consideration provided in Reference 1.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M;FIHCNVET

WO 04-0042 Page 2 The proposed revision to Condition D was reviewed by the Plant Safety Review Committee and the Nuclear Safety Review Committee.

There are no commitments associated with this submittal. Please contact me at (620) 364-4246 or Mr. Kevin Moles at (620) 364-4126 for any questions regarding this submittal.

Very truly yours, Jacobs DJ/rIg Attachments:

I Proposed Revision to Technical Specifications 11 -

Proposed Revision to Technical Specification Bases (for information only) cc:

V. L. Cooper (KDHE), w/a J. N. Donohew (NRC), w/a D. N. Graves (NRC), w/a B. S. Mallett (NRC), w/a Senior Resident Inspector (NRC), w/a

STATE OF KANSAS

)

) Ss COUNTY OF COFFEY )

Donna Jacobs, of lawful age, being first duly sworn upon oath says that she is Vice President Operations and Plant Manager of Wolf Creek Nuclear Operating Corporation; that she has read the foregoing document and knows the contents thereof; that she 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 her knowledge, information and belief.

By Donna Jacob Vice Preside perations and Plant Manager SUBSCRIBED and sworn to before me this 'l day of 0C+, 2004.

I.

RHONDA L GLEUE Notary Public Expiration Date L67 l I d

Attachment I to WO 04-0042 Page 1 of 3 ATTACHMENT I PROPOSED REVISION TO TECHNICAL SPECIFICATIONS

Attachment I to WO 04-0042 Page 2 of 3 RTS Instrumentation 3.3.1 (continued)

Wolf Creek - Unit 1 3.3-3 Amendment No. 123

Attachment I to WO 04-0042 Page 3 of 3 INSERT 3.3.1.D CONDITION REQUIRED ACTION COMPLETION

__________________________________TIME D. One Power Range Neutron Flux - High channel inoperable.

--- NOTE--

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing and setpoint adjustment of other channels.

D.1.1

--- NOTE--

Only required when the Power Range Neutron Flux input to QPTR is inoperable.

Perform SR 3.2.4.2.

AND D.1.2 Place channel in trip.

OR 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery of THERMAL POWER > 75%

RTP AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> D.2 Be in MODE 3.

78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> 1 to WO 04-0042 Page 1 of 4 ATTACHMENT 11 PROPOSED REVISION TO TECHNICAL SPECIFICATION BASES (for information only)

Attachment II to WO 04-0042 Page 2 of 4 RTS Instrumentation B 3.3.1 BASES ACTIONS C.1, C.2.1 and C.2.2 (continued)

This action addresses the train orientation of the SSPS for these Functions. With one channel or train inoperable, the inoperable channel or train must be restored to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the affected Function(s) cannot be restored to OPERABLE status within the allowed 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time, the unit must be placed in a MODE in which the requirement does not apply. To achieve this status, action must be initiated within the same 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to fully insert all rods and the Rod Control System must be rendered incapable of rod withdrawal within the next hour (e.g., by de-energizing all CRDMs, by opening the RTBs, or de-energizing the motor generator (MG) sets). The additional hour for the latter provides sufficient time to accomplish the action in an orderly manner. With the rods fully inserted and Rod Control System incapable of rod withdrawal, these Functions are no longer required.

The Completion Time is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function, and given the low probability of an event occurring during this interval.

Condition C is modified by a Note stating that while this LCO is not met for Function 19, 20, or21 in MODE 5, making the Rod Control System capable of rod withdrawal is not permitted. This Note specifies an exception to LCO 3.0.4 for this MODE 5 transition and avoids placing the plant in a condition where control rods can be a withdrawn or not fully inserted while the Reactor Trip System is degraded.

D.1.1, D.1.2, fi 12Y_

bI-Condition D applies to the Power Range Neutron Flux-High Function.

I 1The NIS power range detectors provide input to the Rod Control System and, therefore, have a two-out-of-four trip logic. A known inoperable channel must be placed in the tripped condition. This results in a partial trip condition requiring only one-out-of-three logic for actuation. The 72 )

Xhours allowed to place the inoperable channel in the tripped condition is

-/

justified in

/ _

e mo ble chaiel in the pped co

ition, ER L POW must b reduced

< 75% R within hours.

Reding the Cwer leve revents eration o he core ith radi ower di ibutions eyond t design Iits at a poIer level ere D nditions ay exis With on of the NIS ower ra e detec rs inopra e 1/

of radal er dstritio mo orig cabits sf Wolf Creek - Unit 1 B 3.3.1-32 Revision 0

Attachment II to WO 04-0042 Page 3 of 4 INSERT 1 With one of the NIS power range detectors inoperable, 1/4 of the radial power distribution monitoring capability is lost.

Therefore, SR 3.2.4.2 must be performed (Required Action D.1.1) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of THERMAL POWER exceeding 75% RTP and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

Calculating QPTR every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> compensates for the lost monitoring capability due to the inoperable NIS power range channel and allows continued unit operation at power levels > 75%

RTP. At power levels < 75% RTP, operation of the core with radial power distributions beyond the design limits, at a power level where DNB conditions may exist, is prevented. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is consistent with the Surveillance Requirement Frequency in LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)." Required Action D.1.1 has been modified by a Note which only requires SR 3.2.4.2 to be performed if the Power Range Neutron Flux input to QPTR becomes inoperable. Failure of a component in the Power Range Neutron Flux Channel which renders the High Flux Trip Function inoperable may not affect the capability to monitor QPTR. As such, determining QPTR using movable incore detectors may not be necessary.

Attachment II to WO 04-0042 Page 4 of 4 RTS Instrumentation B 3.3.1 BASES(

}

ACTIONS D.1.1, D.1.2, (continued)

As a a tern e to th bove actio s, the inop ible char del can be p ped in t tripped ondition wi n 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> d the QP R monito d ce ev 12 ho as per S

.2.4.2 (inc ding the 3.2.4.2 te),

QPT erificati

. Calculatig QPTR ev 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> compen es for th ost monit ring capabV y due to the noperable IS pow range Iannel anallows co *nued unit o ration at wer level

> 75% TR The 6 hoper Completin Time and e 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> requency re consi ent LA NT P WER TILT /RTIO O

Co As an alternative to the above Actions, the plant must be placed in a MODE where this Function is no longer required OPERABLE.

(SeverteSXZ: (-8z)

,hours are allowed to place the plant in MODE 3.kThis is a reasonable time, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging plant systems. If Required Actions cannot be completed within their allowed Completion Times, LCO 3.0.3 must be entered.

The Required Actions have been modified by a Note that allows placing{

the inoperable channel in the bypass condition for up to ours while performing routine surveillance testing of other channels. The Note also allows placing the inoperable channel in the bypass condition to allow

.setpoint adjustments of other channels when required to reduce the setpoint in accordance with other Technical Specifications. Thegour time limit is justified in Reference equir Od Acti 0..

een dified bf a Note hiho require s SR.2.4.2 t e perfo ed if th Power ange N itron Fl x input TR be mes ino rable. F ilure of compo ent in te Powey4Range eutron lux Cha nel whic renders e High lux TnrFunctior

/

inope ble may ot affect e capa ity to nitor Q R. Asuch, /

det mining TR usi the mov ble inc e dete ors onc per othors y not b necessa E.1 and E.2 Condition E applies to the following reactor trip Functions:

Power Range Neutron Flux -Low; Overtemperature AT; Overpower AT; 7Ihc. 76-hmouA-r ieA Trn s

nc sclx8-72 Vicxavs -Gcrv6anrneA crt~eVLv maivej&ns c

C-Latwi.

ta m p hc It.c5 t MbDe riaLctb6rs

0.

rewuee bx uire Ac-htt6" TD.?.

Wolf Creek - Unit 1 B 3.3.1-33 Revision 0