WO 06-0041, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification (TS) 3.7.2, Main Steam Isolation Valves (Msivs), and TS 3.7.3, Main Feedwater Isolation Valves (Mfivs)

Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification (TS) 3.7.2, Main Steam Isolation Valves (Msivs), and TS 3.7.3, Main Feedwater Isolation Valves (Mfivs)

ML063040662
Person / Time
Site:	Wolf Creek
Issue date:	10/25/2006
From:	Hedges S Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WO 06-0041
Download: ML063040662 (6)

Text

W0Lý-'tF CREEK NUCLA OPERATING CORPORATION Stephen E. Hedges Vice President Operations and Plant Manager October 25, 2006 WO 06-0041 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

Letter WM 06-0033, dated August 25, 2006, from M. W. Sunseri, WCNOC, to USNRC

Subject:

Docket No. 50-482: Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification (TS) 3.7.2, "Main Steam Isolation Valves (MSIVs),"

and TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs)"

Gentlemen:

The Reference provided Wolf Creek Nuclear Operating, Corporation's (WCNOC) application to revise Technical Specification (TS) 3.7.2, "Main Steam Isolation Valves (MSIVs)," and TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs)," to incorporate the MSIV actuator trains and MFIV actuator trains into the Limiting Condition for Operation (LCO) and provide associated Conditions and Required Actions. On October 12, 20Q6, the Nuclear Regulatory Commission (NRC) provided a request for additional information (RAI) via electronic mail. A draft response to the RAI was provided via electronic mail on October 18, 2006.

Attachment I provides a response to the question provided by electronic mail. Attachment II provides a revised TS 3.7.3 page as discussed in the response to the RAI.

The additional information provided in the Attachments does not impact the conclusions of the No Significant Hazards Consideration provided in the Reference. In accordance with 10 CFR 50.91, a copy of this submittal is being provided to the designated Kansas State official.

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

WO 06-0041 Page 2 This submittal contains no commitments, If you have any questions concerning this matter, please contact me at (620) 364-4190, or Mr. Kevin Moles at (620) 364-4126.

Very truly y rs, St ph E. Hedges SEH/rlt Attachments cc: T. A. Conley (KDHE), w/a J. N. Donohew (NRC), w/a G. E. Werner (NRC), w/a B. S. Mallett (NRC), w/a Senior Resident Inspector (NRC), w/a

STATE OF KANSAS )

) SS COUNTY OF COFFEY )

Stephen E. Hedges, of lawful age, being first duly sworn upon oath says that he is Vice President Operations and Plant Manager 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.

Steph .fedges Vice e ent Operations and Plant Manager SUBSCRIBED and sworn to before me thisS day of b-'. , 2006.

bCINDY NOVINGER Notary PubIk fýaý U STTEOFKANSASMy Appt. Exp. -a Expiration Date

Attachment I to WO 06-0041 Page 1 of 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION This Attachment provides Wolf Creek Nuclear Operating Corporation's (WCNOC) response to the Nuclear Regulatory Commission (NRC) request for additional information (RAI) received via electronic mail on October 12, 2006.

1. In the application dated 08/25/06, it has been proposed to retain "Separate Condition Entry" (SCE) for tracking Completion Times in the MFIV TS 3.7.3 (the Note for TS 3.7.3) and but this has not been proposed in the MSIV TS 3.7.2. Using the SCE notation to the limiting condition for oper'ation (LCO) ACTIONS modifies how the Completion Time is tracked.

The TS 3.4.3 [3.7.3] Note allows each of the LCO 3.7.3 Conditions to be entered separately for each inoperable valve and actuator train, and Completion Times tracked on a per component (valve or actuator train) basis. Therefore, Wolf Creek Nuclear Operating Corporation (WCNOC) proposed LCO Conditions that address inoperable actuator trains for different MFIVs and inoperable actuator trains for different actuator train separation groups. It is requested that WCNOC prepare guidance to show how the Completion Time Example 1.3-5 convention would apply to the combinations of inoperable components in each of the new Conditions being added to LCO 3.7.3.

Response: A "separate Condition entry" Note was not proposed for Technical Specification (TS) 3.7.2, "Main Steam Isolation Valves (MSIVs)," since current Condition B (proposed Condition H) contains a "separate Condition entry" Note for one or more MSIVs inoperable in MODE 2 or 3. WCNOC is maintaining the "separate Condition entry" Note in TS 3.7.2 consistent with what the NRC approved for the Callaway Plant in License Amendment No. 172 dated June 16, 2006. For TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs)," the "separate Condition entry" Note to the ACTIONS Table is applicable only to the MFIVs and not the actuator trains (i.e., only applies to new Condition F). WCNOC believes that the "separate Condition entry" should be maintained based on the very short Completion Time for new Condition F and maintaining the Note is consistent with NUREG-1431, Rev. 3.1, "Standard Technical Specifications Westinghouse Plants." To eliminate any confusion, WCNOC is proposing to move the Note to Condition F. Attachment II provides a revised TS 3.7.3 markup.

Page 2 of 2 of Attachment II replaces Page 6 of 8 in Attachment II to WM 06-0033.

Attachment II to WO 06-0041 Page 1 of 2 ATTACHMENT II MARKUP OF TECHNICAL SPECIFICATION PAGES

Attachment II to WO 06-0041 Page 2 of 2 MFIVs 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Main Feedwater Isolation Valves (MFIVs)

LCO 3.7.3 Four MFIVs shall be OPERABLE.

APPLICABILITY: .MODES 1, 2, and 3.

ACTIONS

-One or more MFIVs 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable.

AND F

• Verify MFIV is closed. Once per 7 days Required Action and Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> CLA associated Completion Time not met. :AND E Bee in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Wolf Creek - Unit 1 3.7-7 Amendment No. 123