ML060590063

Issuance of Amendment Changes to the Reactor Coolant System (RCS) Leakage Detection Instrumentation Methodology (MC8214)

ML060590063
Person / Time
Site:	Wolf Creek
Issue date:	09/26/2006
From:	Donohew J NRC/NRR/ADRO/DORL/LPLIV
To:	Muench R Wolf Creek
Donohew J N, NRR/DORL/LP4, 415-1307
References
TAC MC8214
Download: ML060590063 (16)

Text

September 26, 2006Mr. Rick A. MuenchPresident and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - ISSUANCE OF AMENDMENT RE: CHANGES TO THE REACTOR COOLANT SYSTEM (RCS) LEAKAGE DETECTION INSTRUMENTATION METHODOLOGY (TAC NO. MC8214)

Dear Mr. Muench:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosedAmendment No. 166 to Facility Operating License No. NPF-42 for the Wolf Creek GeneratingStation (WCGS). The amendment consists of changes to the operating license in response to your application dated June 26, 2006 (ET 06-0024). This application superceded the license amendment request in your application dated August 26, 2005 (ET 05-0007), as supplemented by letter dated November 18, 2005 (ET 05-0022).The amendment revises Technical Specification (TS) 3.4.15, "RCS [Reactor Coolant System]Leakage Detection Instrumentation." The TS changes delete the containment atmospheregaseous radioactivity monitor from TS 3.4.15 and revise the existing conditions, required actions, completion times, and surveillance requirements in TS 3.4.15 to account for themonitor being deleted.A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included inthe Commission's next biweekly Federal Register notice.Sincerely,/RA/Jack Donohew, Senior Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-482

Enclosures:

1. Amendment No. 166 to NPF-422. Safety Evaluationcc w/encls: See next page

Pkg ML062690257 (ML060590063, TS ML062700063)OFFICELPL4/PMLPL4/LAITSB/BCSBPB/ABCCFEB/BCOGCLPL4/BCNAMEJDonohewLFeizollahiTKobetzJSegalaKGrussJRund NLODTerao DATE9/22/069/22/068/22/068/24/063/14/069/19/069/22/06 WOLF CREEK NUCLEAR OPERATING CORPORATIONWOLF CREEK GENERATING STATIONDOCKET NO. 50-482AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 166License No. NPF-421.The Nuclear Regulatory Commission (the Commission) has found that:A.The application dated June 26, 2006, for amendment to the Wolf Creek GeneratingStation (the facility) Facility Operating License No. NPF-42 filed by the Wolf Creek Nuclear Operating Corporation (the Corporation) complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, as amended, theprovisions of the Act, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by this amendmentcan be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission'sregulations;D.The issuance of this license amendment will not be inimical to the common defenseand security or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, the license is also amended by changes to the Technical Specifications asindicated in the attachment to this license amendment and Paragraph 2.C.(2) of FacilityOperating License No. NPF-42 is hereby amended to read as follows:2.Technical SpecificationsThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 166, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the TechnicalSpecifications and the Environmental Protection Plan.3.This license amendment is effective as of its date of issuance and shall be implementedwithin 90 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA/David Terao, ChiefPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical SpecificationsDate of Issuance: September 26, 2006 ATTACHMENT TO LICENSE AMENDMENT NO. 166FACILITY OPERATING LICENSE NO. NPF-42DOCKET NO. 50-482Replace the following pages of the Appendix A Technical Specifications with the attachedpages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. The corresponding overleaf pages are provided to maintain document completeness.REMOVEINSERT3.4-373.4-373.4-383.4-38 3.4-393.4-39 3.4-403.4-40 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 166 TO FACILITY OPERATING LICENSE NO. NPF-42WOLF CREEK NUCLEAR OPERATING CORPORATIONWOLF CREEK GENERATING STATIONDOCKET NO. 50-48

21.0INTRODUCTION

By application dated June 26, 2006 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML061860316), Wolf Creek Nuclear Operating Corporation (the licensee) requested changes to the facility operating license for the Wolf Creek GeneratingStation (WCGS). The license amendment request would revise Technical Specification (TS) 3.4.15, "RCS [Reactor Coolant System] Leakage Detection Instrumentation." The proposed TS changes would delete the containment atmosphere gaseous radioactivity monitor from TS 3.4.15 and revise the existing conditions, required actions, completion times, and surveillance requirements in TS 3.4.15 to account for the monitor being deleted.This application superceded the license amendment request dated August 26, 2005, and itssupplemental letter dated November 18, 2005 (ADAMS Accession Nos. ML052510236 and ML053410415, respectively), which provided information on the containment atmosphere gaseous radioactivity monitor. The license amendment request in the letter dated August 26, 2005, requested changes to Appendix 3A, Section 5.2.5.2.3, and Table 5.2-6 of the UpdatedSafety Analysis Report (USAR) for WCGS that would revise the methodology for the reactor coolant system (RCS) leak detection instrumentation to clarify the design of the containmentatmosphere gaseous radioactivity monitor with regard to the required RCS leak detection capability in TS 3.4.15.

2.0REGULATORY EVALUATION

In 10 CFR 50.36, the NRC issued a rule and established its regulatory requirements related tothe content of TSs. In doing so, the NRC emphasized those matters related to the preventionof accidents and mitigation of consequences of such accidents. As recorded in the Statementsof Consideration, Technical Specifications for Facility Licenses: Safety Analysis Reports(33 FR 18610, December 17, 1968), the NRC noted that licensees are expected to incorporateinto their plant TSs those items that are directly related to maintaining the integrity of thephysical barriers designed to contain radioactivity. Pursuant to 10 CFR 50.36, TSs are required to include items in five specific categories related to station operation. Specifically, those categories include: (1) safety limits, limiting safety system settings (LSSSs), and limiting controlsettings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. However, the rule does not specify thespecific requirements to be included in a plant

<s TSs.Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether aLCO is required to be included in the TS for a certain item. These criteria are as follows:1.Installed instrumentation that is used to detect, and indicate in the control room, asignificant abnormal degradation of the reactor coolant pressure boundary (RCPB).2.A process variable, design feature, or operating restriction that is an initial condition of adesign basis accident or transient analysis that either assumes the failure of or presentsa challenge to the integrity of a fission product barrier.3.A structure, system, or component (SSC) that is part of the primary success path andwhich functions or actuates to mitigate a design basis accident or transient that eitherassumes the failure of or presents a challenge to the integrity of a fission product barrier.4.A SSC which operating experience or probabilistic risk assessment has shown to besignificant to public health and safety.As stated in 10 CFR 50.36(c)(2)(i), LCOs "are the lowest functional capability or performancelevels of equipment required for safe operation of the facility. When a [LCO] of a nuclearreactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications ..." The remedial actions in the TSs are specified interms of LCO conditions, required actions, and completion times (CTs) to complete the required actions. When an LCO is not being met, the CTs specified in the TSs are the time allowed in the TSs for completing the specified required actions. The conditions and required actions specified in the TSs must be acceptable remedial actions for the LCO not being met, and the CTs must be a reasonable time for completing the required actions.General Design Criterion (GDC) 4, "Environmental and dynamic effects design bases," ofAppendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, requires, in part,that "dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditionsconsistent with the design basis for the piping." The Nuclear Regulatory Commission (NRC)allows the application of leak-before-break (LBB) technology on the primary piping systemsunder the broad-scope revision to 10 CFR Part 50, Appendix A, GDC 4 (Volume 52 of the Federal Register pages 41288-41295, October 27, 1987). Specific guidance on LBB evaluationis discussed in draft Standard Review Plan (SRP) 3.6.3, "Leak-Before-Break Evaluation Procedures." Additional guidance can be found in NUREG-1061, "Report of the U.S. NuclearRegulatory Commission Piping Review Committee," Volume 3, "Evaluation of Potential for PipeBreaks," dated November 1984. In the statements of considerations for SRP 3.6.3 (Volume 52of the Federal Register pages 32626-32633, August 28, 1987), the NRC stated that (1)"Leakage detection systems are evaluated to determine that they are sufficiently reliable,redundant , and sensitive so that margin on detection of unidentified leakage exists for the throughwall flaws used in the deterministic fracture mechanics evaluation" and (2) "Leak detection systems equivalent to Regulatory Guide [RG] 1.45, 'Reactor Coolant PressureBoundary Leakage Detection Systems,' Revision 0, dated May 1973, are required for the piping under evaluation inside the containment."GDC 30, "Quality of reactor coolant pressure boundary," requires, in part, that means beprovided for detecting and, to the extent practical, identifying the location of the source of RCS leakage. RG 1.45 describes acceptable methods of implementing this requirement with regard to the selection of leakage detection systems for the RCPB. Theposition of RG 1.45 is that at least three different detection methods should be employed. Twoof these methods should be: (1) sump level and flow monitoring, and (2) airborne particulate radioactivity monitoring. The third method may involve either monitoring of a condensate flow rate from air coolers or monitoring of gaseous radioactivity. The RG recommends that the sensitivity and response time of each leakage detection system employed for unidentifiedleakage should be adequate to detect a leakage rate, or its equivalent, of 1 gallon per minute (gpm) in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The GDC 30 requirement for systems to detect RCS leaks tomaintain the quality of the RCPB is the same requirement in GDC 4 to detect RCS leakage for LBB; therefore, the requirements on RCS leakage detection systems to meet GDC 30 are thesame as those to meet LBB of GDC 4, which is redundant RCS leak detection systems that areequivalent to the systems listed in RG 1.45.

The licensee states, in Appendix 3A of the USAR, that the recommendations of RG 1.45 aremet as described in USAR Table 5.2-6. In USAR Table 5.2-6, the licensee states that itcomplies with regulatory position C.5 on sensitivity and response time of each leakage detection system as described in USAR Section 5.

2.5.2.3 and as shown on Figure 5.2-2.3.0NRC STAFF SAFETY EVALUATION3.1Current RCS Leak Detection RequirementsThe current RCS leakage detection requirements for WCGS are given in TS 3.4.15. It requiresthe following RCS leakage detection instrumentation shall be operable.5.The containment sump level and flow monitoring system, 6.One containment atmosphere particulate radioactivity monitor, and 7.One containment air cooler condensate monitoring system or one containmentatmosphere gaseous radioactivity monitor.LCO 3.4.15 and Surveillance Requirements (SRs) 3.4.15.1 through 3.4.15.5 do not specify theRCS leak detection criteria. TS 3.4.15 only requires that the specified equipment is operableand SRs 3.4.15.1 through 3.4.15.5 specify the surveillances that are required to determine if thedetection instrumentation is operable (i.e., a channel check, channel operational test, and channel calibration, as applicable) and the frequency for conducting the surveillances. Therequired RCS leak detection capability of the equipment given in TS 3.4.15 is the capabilitygiven in Position C.5 of RG 1.45 as modified by the licensee's commitment to RG 1.45 in Appendix 3A of the WCGS USAR.3.2Superceded Application Dated August 26, 2005 In its application dated August 26, 2005, the licensee stated that the containment gaseousradioactivity monitor listed in LCO 3.4.15 cannot detect a 1 gpm RCS leak in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at the current RCS radioactivity levels, however, the licensee only proposed to revise the USAR description of the monitor. In not proposing to delete the monitor from LCO 3.4.15, where theother systems and instrumentation listed in LCO 3.4.15 are currently capable of detecting suchRCS leakage in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the licensee was requested to explain why the containment gaseous radioactivity monitor should remain in the TSs. In the amendments No. 140 (both units), for Byron Station, Units 1 and 2, and No. 133 (both units), for Braidwood Station, Units 1 and 2,dated January 14, 2005 (ADAMS Accession no. ML043550025), addressing the containment gaseous radioactivity monitor at these plants not being capable of detecting a 1 gpm RCS leak in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the licensee for the Byron and Braidwood Stations had proposed to remove the monitor from the Byron and Braidwood LCO 3.4.15, "RCS Leakage Detection Instrumentation," and the NRC approved the change in the amendments. Therefore, the NRC staff questionedthe licensee about why the containment gaseous radioactivity monitor met the criteria in 10 CFR 50.36(c)(2)(ii) to remain in LCO 3.4.15.In its application dated August 26, 2005, and supplemental letter dated November 18, 2005, thelicensee addressed the staff's question on why the containment gaseous radioactivity monitor should remain in the LCO 3.4.15. The licensee stated that, if the containment gaseousradioactivity monitor was removed from LCO 3.4.15.c, the remaining detection methods in LCO 3.4.15 would be three methods that meet the one RCS leak rate in one hour, which meetRG 1.45 Position C.3 that requires at least three separate detection methods, and maintainingthree methods in LCO 3.4.15 would provide a basis for deleting the monitor from LCO 3.4.15. The licensee also stated that TS 3.4.15 has the objective of supporting GDC 30 on the qualityof the RCS pressure boundary by requiring a diverse set of RCS leakage detection methods to ensure there are effective means under varying plant conditions of detecting leakage through the pressure boundary. Therefore, the licensee concluded that it is prudent to have methodsthat include sufficient systems and instrumentation to assure effective monitoring during allperiods of operation which would include periods when some detection methods are in fact ineffective. The licensee also discussed plant conditions in addition to low RCS activity whereby the containment atmosphere has a radioactivity level that would mask the change inradioactivity that would correspond to the containment gaseous radioactivity monitor being able to detect a 1 gpm RCS leak rate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. In conclusion, in addressing the criteria in 10 CFR 50.36(c)(2)(ii) for SSCs to be in LCOs, in Section 5.2 of Attachment 1 to its August 26, 2005, application, the licensee stated that paragraph 50.36(c)(2)(ii)(A) specifies that an LCO must beestablished for "installed instrumentation that is used to detect, and indicate in the control room,a significant abnormal degradation of the reactor coolant pressure boundary." The licensee stated that the instrumentation listed in TS 3.4.15, including the containment gaseousradioactivity monitor when the RCS radioactivity is high enough, meets this criterion.In its review of the licensee's application, the NRC staff considered the licensee's argument thatthe containment gaseous radioactivity monitor is not capable of detecting a 1 gpm leak rate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at all times. It is true that the RCS radioactivity levels where the containment gaseous radioactivity monitor will detect 1 gpm leak rate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> are within the limits allowed byTS 3.4.16, where plant operation is allowed, and that these monitors provide diversity indetecting RCS leakage; however, the RCS radioactivity levels where these monitors will meetthis criteria are plant conditions that are not currently normally expected to be present in theRCS coolant at WCGS. In its letter of May 16, 2006, to the licensee, the NRC staff stated the following:RG 1.45 states that "in analyzing the sensitivity of leak detection systems using airborneparticulate or gaseous radioactivity, a realistic primary coolant radioactivity concentration assumption should be used" and a realistic concentration would be that which is currently normally expected to be present in the RCS coolant. Although RG 1.45 also states that the coolant radioactivity concentration values in the plant environmentalreport would be acceptable as the realistic primary coolant radioactivity concentration, this statement would no longer be correct if the values in the plant environmental report are significantly higher than the values that would be currently expected in the RCScoolant. and requested the following:Because TS 3.4.15 defines the RCS leakage detection instrumentation being reliedupon to meet the criterion of detecting a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for normal plant conditions, we are requesting that you either provide justification that the containmentgaseous radioactivity monitor can meet this criterion or revise your amendment request dated August 26, 2005, to remove the containment gaseous radioactivity monitor from TS 3.4.15. The licensee responded in its supplemental letter dated June 26, 2006. This letter submittedchanges to TS 3.4.15 and withdrew the license amendment request to authorize changes to the USAR.3.3Proposed Change to TS 3.4.15 By letter dated June 26, 2006, the licensee proposed to remove the containment gaseousradioactivity monitor from LCO 3.4.15 by proposing the following changes to TS 3.4.15:1.Delete the phrase "or one containment atmosphere (gaseous) radioactivity monitor"from LCO 3.4.15.c. Therefore, only the containment air cooler condensate monitoringsystem remains in LCO 3.4.15.c.2.Re-number existing Required Action B.2 such that it is B.2.1 and add the RequiredAction B.2.2 to "verify containment air cooler condensate monitoring system isOPERABLE" with a completion time (CT) of 30 days. For Condition B, the licensee would do either the re-number Required Action B.2.1, which it or its CT is not being changed in this amendment, or the new Required Action B.2.2.3.The existing Condition C is re-numbered as Condition D and a new Condition C for therequired containment cooler condensate monitoring system being inoperable is addedwith the following required actions: (1) Required Action C.1 to perform SR 3.4.5.1 once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and (2) Required Action C.2 to perform SR 3.4.13.1 once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.4.The existing Condition C is revised to replace the reference to an inoperablecontainment atmosphere gaseous radioactivity monitor by a reference to an inoperablecontainment atmosphere particulate radioactivity monitor. The reference to an inoperable containment cooler condensate monitoring system is not being changed. This condition is re-numbered Condition D.5.The required actions for existing Condition C are revised by (a) deleting RequiredActions C.1.1 and C.1.2, (b) re-numbering Required Actions C.2.1 and C.2.2 as Required Actions D.1 and D.2, and (c) replacing the reference to an inoperablecontainment atmosphere gaseous radioactivity monitor by a reference to an inoperablecontainment atmosphere particulate radioactivity monitor.6.Existing Conditions D and E, and the associated required actions, are re-numbered asConditions E and F.7.Remove references to the containment atmosphere gaseous radioactivity monitor fromSRs 3.4.15.1, 3.4.

15.2, and 3.4.15.4.3.3.1Removal of a RCS Leakage Detection Instrument from LCO 3.4.15 As stated in the NRC letter of May 16, 2006, to the licensee, the RG 1.45 criteria in regulatoryposition C.5, for the sensitivity and response time of the leakage detection systems, ofdetecting a 1 gpm RCS leak in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> would be met for normal plant conditions. This criterion is required for the RCS detection instrumentation listed in TS 3.4.15, which includes thecontainment atmosphere gaseous radioactivity monitor. In its applications dated August 26, 2005, and June 26, 2006, the licensee stated that the other instrumentation listed in LCO 3.4.15meet this criterion.The reference to normally expected plant conditions in the NRC letter of May 16, 2006, forWCGS for radioactivity in the RCS is the current level of radioactivity in the core at WCGS with no or minor fuel cladding defects. The licensee stated that its evaluation of the sensitivity and response time of the containment atmosphere gaseous radioactivity monitor, using the current level of radioactivity in the reactor coolant at WCGS with no or minor fuel cladding defects and a realistic nominal detector background level, has shown that this monitor would not promptly detect a 1 gpm RCS leak in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Because the containment atmosphere gaseous radioactivity monitor can not meet this criteria for normally expected plant conditions, the licensee has proposed to remove this instrument from LCO 3.4.15 and, therefore, LCO 3.4.15.cwould only list the containment cooler condensate monitoring system. The licensee stated thatthe remaining RCS leakage detection instruments in LCO 3.4.15 provide adequate capability topromptly detect RCS leakage.Because the licensee stated that the containment atmosphere gaseous radioactivity monitor isunable to meet the RG 1.45 criteria for normally expected plant conditions, the NRC staffconcludes that this RCS leakage detection instrument does not meet any of the four criteria in10 CFR 50.36(c)(2)(ii) , see Section 2.0 of this SE, for an instrument being included in an LCO in the TSs. Based on this, the NRC staff further concludes that the proposed removal of thisinstrument from LCO 3.4.15 is acceptable because the amended TS 3.4.15 meets the criteriaset by RG 1.45 for leak detection and diversity of instruments, and, therefore, the remainingRCS leakage detection instruments in LCO 3.4.15 provide adequate capability to promptlydetect RCS leakage. 3.3.2Changes to the Remedial Actions for Not Meeting LCO 3.4.15In the existing TS 3.4.15.c, the containment cooler condensate monitoring system or thecontainment atmosphere gaseous radioactivity monitor is required to be operable and, as a remedial action when existing LCO 3.4.15.c is not being met, there is existing Condition C for the condition where both the required monitor and monitoring are inoperable. In removing the containment atmosphere gaseous radioactivity monitor from LCO 3.4.15.c, the licensee hasalso proposed to revise the conditions and required actions for the LCO. This is to (1) propose a new condition for only the containment cooler condensate monitoring system beinginoperable and (2) remove the references to the containment atmosphere gaseous radioactivity monitor in the conditions and required actions.For the condition when the containment cooler condensate monitoring system is inoperable, thelicensee has proposed required actions to perform (1) a channel check of the required containment atmosphere particulate radioactivity monitor once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (per SR 3.4.15.1) or (2) a water inventory balance (per SR 3.4.13.1) once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. For the water inventory balance, there is the note that states SR 3.4.13.1 is not required to be performed until 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />safter establishment of steady state operation. Twelve hours after steady state operation, thewater inventory balance would then be performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This is the same note that is stated in the existing SR 3.4.13.1.The licensee has also revised the existing remedial actions in existing Condition B (the requiredcontainment atmosphere particulate radioactivity monitor inoperable) and existing Condition C (the required containment atmosphere gaseous radioactivity monitor and cooler condensate monitoring system inoperable) to join or tie together the containment atmosphere particulateradioactivity monitor with the containment air cooler condensate monitori ng system. Forexisting Condition B, the Required Action B.2.2 would be added so that the existing RequiredAction B.2 (re-numbered B.2.1), which requires that the containment atmosphere particulateradioactivity monitor is restored to operable status is met within 30 days or the licensee would verify that the containment air cooler condensate monitori ng system is operable within that30 days.For existing Condition C (the required containment atmosphere gaseous radioactivity monitorand cooler condensate monitoring system inoperable), the licensee has proposed to (1) replacethe reference to the atmosphere gaseous radioactivity monitor by the reference to the atmosphere particulate radioactivity monitor, (2) delete Required Actions C.1.1 and C.1.2 to analyze samples of the containment atmosphere or verify RCS operational leakage is within limits by performance of a RCS water inventory balance (SR 3.4.13.1) once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and (3) re-number the existing Required Actions C.2.1 and C.2.2 to restore the containment atmosphere particulate radioactivity monitor, which replaces the reference to the atmosphere gaseous radioactivity monitor in the existing required action, or the containment air cooler condensate monitoring system within 30 days.For the new Condition C, which is for the containment air cooler condensate monitoring systeminoperable by itself, the licensee proposed the new Required Actions C.1 and C.2 to perform a channel check of the required containment atmosphere particulate radioactivity monitor (SR 3.4.15.1) once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or to verify RCS operational leakage is within limits byperformance of a RCS water inventory balance (SR 3.4.13.1) once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.The licensee stated that the proposed changes to remove the containment atmospheregaseous radioactivity monitor from the remedial actions for LCO 3.4.15 (i.e., the changes to existing Conditions B and C, and the addition of the new Condition C) are acceptable because of the availability of the two other diverse methods required by LCOs 3.4.15.a (containmentsump level and flow monitoring system) and 3.4.15.b (containment atmosphere particulateradioactivity monitor) to detect RCS leakage and the impracticality of containment entries at power to repair the containment air cooler condensate monitoring system.The NRC staff has reviewed the above changes to the remedial actions for LCO 3.4.15 and hasdetermined that the 24-hour interval provides periodic information that is adequate to detectleakage. The 12-hour allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. The 30-day CT recognizes that other formsof RCS leakage detection are available. Based on this determination, the NRC staff concl udesthat the proposed changes are acceptable.Due to the addition of new condition C, the licensee re-numbered existing Conditions D and E. These changes are considered editorial in nature. Therefore, based on this, the NRC staffconcludes that the proposed renumbering of Conditions D and E is acceptable.3.3.3Changes to the SRs for LCO 3.4.15 To remove the containment atmosphere gaseous radioactivity monitor from TS 3.4.15, thelicensee has also proposed to delete the reference to this monitor in SRs 3.4.15.1, 3.4.15.2,and 3.4.15.4. These changes only remove this monitor from the SRs in TS 3.4.15. Theexisting SR 3.4.15.5 on the containment air cooler condensate monitori ng system is not beingchanged by this amendment.Because the containment atmosphere gaseous radioactivity monitor is being removed fromTS 3.4.15 and the proposed changes to SRs 3.

4.15.1, 3.4.15.2, and 3.4.15.4 are only toremove the reference to the monitor from the SRs for TS 3.4.15, the NRC staff concludes thatthe proposed changes are editorial in nature and are, therefore, acceptable.3.4LBB The licensee also addressed LBB at WCGS in its applications dated August 26, 2005, andJune 26, 2006, because NRC approval of LBB for RCS piping is based on the licensee's abilityto detect RCS leakage by the methods listed in LCO 3.4.15. The NRC LBB guidance isprovided in NUREG-1061, Volume 3. In that document, the criteria for LBB being approved forpiping includes that the leakage flaw size should be large enough so that the leakage isassured of detection using the minimum installed leak detection capability. This "minimuminstalled leak detection capability" is the instrumentation specified in the plant TSs to detectRCS leakage, which for WCGS are the methods listed in LCO 3.4.15. Therefore, the NRC staffreviewed the application dated June 26, 2006, to determine if the proposed change to thedesign and operability requirements of the containment atmosphere gaseous radioactivitymonitor and the proposed removal of the monitor from TS 3.4.15 would affect the previous NRC approvals of LBB for WCGS.The licensee stated that the change to the design and operability requirements for thecontainment gaseous radioactivity monitor does not affect the basis by which NRC approvedLBB for WCGS. The licensee stated that the basis for NRC's approval of previous LBBanalysis for WCGS continues to be supported by TS 3.4.15, and, thus, supported by themonitor being removed from LCO 3.4.15. Discounting the containment gaseous radioactivitymonitor, LCO 3.4.15 still requires at least two RCS leakage detection instrumentation which arespecified in RG 1.45; therefore, without the containment gaseous radioactivity monitor,LCO 3.4.15 meets the requirement for LBB of there being redundant leakage detection systemsin the TSs that are equivalent to the RCS leak detection systems in RG 1.45. TS 3.4.15requires three means of RCS leak detection that are listed in RG 1.45. Based on this, the NRCconcludes that the proposed change to remove the containment atmosphere gaseousradioactivity monitor from TS 3.4.15 and keep the remaining detection methods in TS 3.4.15meets the GDC 4 requirements for LBB and is, therefore, acceptable.3.5Conclusions The NRC staff has reviewed the licensee's proposal to delete the containment atmospheregaseous radioactivity monitor from TS 3.4.15. The licensee has explained that the monitor does not detect RCS leakage to the criteria in RG 1.45 for the RCS leak age detecti on systemsfor normally expected plant conditions. Based on this, the licensee proposed to remove the monitor from TS 3.4.15. As discussed in Sections 3.3 and 3.4 of this SE, the NRC staffconcludes that the proposed changes to remove the monitor from TS 3.4.15 are acceptableand, therefore, meet 10 CFR 50.36.As discussed in Section 3.4 of this SE, the NRC staff has concluded that the removal of thecontainment atmosphere gaseous radioactivity monitor from TS 3.4.15 also meets GDC 4requirements for LBB. Based on this conclusion, the NRC staff also concludes that theproposed change also meets GDC 30 in that adequate means remain in TS 3.4.15 for detectingRCS leakage and, to the extent practical, identifying the location of the source of RCS leakage.Because the proposed removal of the monitor from TS 3.4.15 meets GDC 4 and 30 and10 CFR 50.36, the NRC staff concludes that the proposed amendment is acceptable. The NRC staff has also reviewed the licensee's identified changes to the TS Bases for thisamendment in Attachment 4 to the licensee's application dated June 26, 2006. The NRC staffhad no disagreement with the changes for the TS Bases.In Attachment IV to its application, the licensee stated the following regulatory commitment: "The license amendment will be implemented within 90 days of issuance. Final TS Baseschanges will be implemented pursuant to TS 5.5.14 at the time the amendment isimplemented." The 90 days referred to in this commitment is the same 90 days stated in the license condition for this amendment whereby the licensee is required to implement the amendment within 90 days. TS 5.5.14 is the program in the TSs for the licensee to make changes to the TS Bases. The NRC staff concludes that this is acceptable.

4.0STATE CONSULTATION

In accordance with the Commission's regulations, the Kansas State official was notified of theproposed issuance of the amendment. The State official had no comments.

5.0ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20. The NRC staff hasdetermined that the amendment involves no significant increase in the amounts, and nosignificant change in the types, of any effluents that may be released offsite, and that there isno 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 and there has been no public comment on such finding (71 FR 41848, July 24, 2006). Accordingly, the amendment meets the eligibility criteria forcategorical exclusion set forth in 10 CFR 51.22(c)(9). 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.

6.0CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) thereis reasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendment will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributor: Jack Donohew Date: September 26, 2006 February 2006Wolf Creek Generating Station cc:Jay Silberg, Esq.

Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW Washington, D.C. 20037Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011Senior Resident InspectorU.S. Nuclear Regulatory Commission

P.O. Box 311 Burlington, KS 66839Chief Engineer, Utilities DivisionKansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027Office of the GovernorState of Kansas Topeka, KS 66612Attorney General120 S.W. 10 th Avenue, 2 nd FloorTopeka, KS 66612-1597County ClerkCoffey County Courthouse

110 South 6 th StreetBurlington, KS 66839Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310Topeka, KS 66612-1366Vice President Operations/Plant ManagerWolf Creek Nuclear Operating Corporation

P.O. Box 411 Burlington, KS 66839Supervisor LicensingWolf Creek Nuclear Operating Corporation

P.O. Box 411 Burlington, KS 66839U.S. Nuclear Regulatory CommissionResident Inspectors Office/Callaway Plant

8201 NRC RoadSteedman, MO 65077-1032