WO 19-0031, Supplement 1 to Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4

Supplement 1 to Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4

ML19227A300
Person / Time
Site:	Wolf Creek
Issue date:	08/08/2019
From:	Mccoy J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-529, Rev 4, WO 19-0031
Download: ML19227A300 (14)

Text

Ja[me H. McCoy Site Vice President August 8, 2019 WO 19-0031 u-. S. Nu.clear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555

References:

1) _ Letter ET 19-0001, dated January 23, 2019, _from $. L. Smith, VVCNOC, to USNRC . .

2) Letter. WO 19-0013, dated March 11, 2019, from J. H. McCoy, WCNOC, to USNRC

Subject:

Docket No. 50-482: Supplement 1 to Application to Revise Technical Specifications* to Adopt TSTF-529, "Clarify Use and Application. Rules,"

Revision 4 To Whom It May Concern:

Ttiis letter is a supplement to Wolf Creek Nuclear Operating Corporation's (WCNOC) request to revise Technical Specifications (TS) *to adopt TSTF-529, "Clarify lJse. and Application Rules,"

Revision 4, whk:h was submitted in Reference 1. .

A'$ a result of subseqyent electronic mail discussions dated July 2~. 2019, between the Nuclear Regu_latory Commisslon Staff and WC NOC Licensing Staff, WCNOC is* proviqing revised TS pages (Attaphments II and Ill, Reference 2).

• These Attachments are updated to provide c9rrection *to the markups and replace Attachments II and Ill of Reference 2 in their entirety.

These changes are con~idered to be editorial changes and are provided as the Enclosure.

The ~ditorial changes to TS Section 1.3 do not impact the conclusions of the No Significant Hazards Consideration provide_d in Reference 1. In-accordance with 10CFR 50.91, "Notice for public comment; State consultation," a copy of this supplement is being provided to the designated Kansas Stat~ official.

" oes ta~t~ cv., CJy:~;,,.,Q P.O. Box 411 / Burlington, KS 66839 / Phone: (620} 364-8831 An Equal Opportunity Employer M/F/HCNET

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WO 19-0031 Page 2 of 3 I

• I This letter contains no regulatory commitments. If you have* any questions concerning this matter, please contact me at (620) 364-4156, or Ron Benham at {6?0) 364-4204.

Sincerely, Jaime H. McCoy JHM/rlt Enclosure cc: S. A. Morris (NRC), w/e N. O'Keefe {NRC), w/e B. K. Singal (NRC), w/e K. S. Steves {KDHE), w/e Senior Resident Inspector (NRC), w/e

WO 19-0031 Page 3 of 3 STATE OF KANSAS ) .*

. ) ss COUNTY OF COFFEY )

• Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Site Vice President 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.

. . .~ °ti rtJ,,c.cl By~ . -------------

Jaime H. McCoy

, Site Vice President

. 0-JI, SUBSCRIBED and sworn to before me this () "t. day of

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,2019.

• OOWWMWOO MyAppokllment . .

Jul124. 202S Jttc~

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ENCLOSURE TO WO 19-0031 REVISED ATTACHMENTS II AND Ill TO LETTER WO 19-0013 (10 PAGES)

Attachment II to WO 19-0013 Page 1 of 5 ATTACHMENT II PROPOSED TECHNICAL SPECIFICATION CHANGES {MARK..UP)

Attachment II to WO 19-0013 Completion Times Page 2 of 5 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time ef discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LC Required Actions must be completed prior to the expiration of the SR i ied Completion Time. An ACTIONS Condition remains in effect and e Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time ef discovery of the situation that required entry into the Condition.,., unless otherwise specified.

Once a Condition has been entered , subsequent trains, subsystems, components, or variables expressed in the Condition , discovered to be inoperable or not within limits, will not result in separate entry into the Condition , unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.,., unless otherwise specified .

(continued)

Wolf Creek - Unit 1 1.3-1 Amendment No. m

Attachment II to 19-0001 Page 3 of 5 INSERT 1.3-1 Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the .Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) is inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s).*

In this case the Completion Time does not begin until the conditions in the Completion are satisfied.

• Attachment 11 to WO 19-0013 Page 4 of 5 LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 specified condition in the Applicability, and establishment of risk (continued) management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or C. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCO 3.1.8, allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

(continued)

Wolf Creek - Unit 1 3.0-2 Amendment No. 123,155,473

Attachment II to WO 19-0013 SR Applicability Page 5 of 5

• 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per .. ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed , from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period , the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered .

(continued)

Wolf Creek - Unit 1 3.0-4 Amendment No. 123, 143, m

Attachment Ill to WO 19-0013 Page 1 of 5 ATTACHMENT Ill RETYPED TECHNICAL SPECIFICATION PAGES

Completion Times 1.3 1.0 USEAND.APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an

. LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation {e.g.,

• I inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

• Unless otherwise specified, the Completion Time begins when a senior

. licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an

• ACTIONS Condition is entered. The uotherwise specified" exceptions are .

• varied, such as a Required Action Note or Surveillance Requirement*

Note that provides.an alternative time*to perform specific tasks, such as .

testing, without starting the Completion Time. While utilizing the Note; a

should Condition be applicable for any reason not addressed by the .

Note, the Cpmpletion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported .by an inoperable diesel generator, inoperable when the redundant required feature{s) is inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B

..concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in ef'fect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations*are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions}, the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that (continued)

Wolf Creek - Unit 1 1.3-1 Amendment No.~ 222

Completion Times 1.3 1.3 Completion Time DESCRIPTION required entry into the Condition, unless otherwise specified.

(continued)

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be .

inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated.* The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered tq be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent

• inoperability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply ta those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero.* This modified "time zero" m,ay be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where 1he Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ...

• Example 1.3-3 illustrates one use of this type of Completion Time. The 1Oday Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

(continued)

Wolf Creek - Unit 1 1.3-2 Amendment No. ~ 222

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 specified condition in the Applicability, and establishment *of risk (continued) management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCO 3.1.8, allows specified Technical Specification {TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is 9ptional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

(continued)

Wolf Creek - Unit 1 Amendment No. 123, 155, 173,222 J

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the

• Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

• For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per ..."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to

• the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance .. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Wolf Creek - Unit 1 3.0-4 Amendment No. ~23, 143,473,222 l