ML20212J795

Advises That plant-specific Analysis of Complete Break Spectrum,Per Requirements of App K to 10CFR50,needed for NRC Approval of 861107 Proposed Mod to Tech Specs to Allow Operation in Mode 3 W/Eccs Sys Partially Disabled

ML20212J795
Person / Time
Site:	Wolf Creek
Issue date:	03/04/1987
From:	Oconnor P Office of Nuclear Reactor Regulation
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8703090136
Download: ML20212J795 (2)

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l Docket No. 50-482 4 MAR 1987 Mr. Bart D. Withers President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 l Burlington, Kansas 66839

Subject:

Revision to Technical Specifications 3.5.1. and 3.5.2 Your letter dated November 7,1986 proposed technical specification modifications which would permit operation in Mode 3 with low pressure injection discharge valves (8809A and 88098) isolated or one accumulator discharge isolation valve (8808A, B, C, or D) isolated for an unlimited length of time and no restriction related to system pressure. Isolation of the valves would result in reduced ECCS flow to the reactor system in the event of a LOCA. Justification for the proposed mode of operation is based on exclusion of large break LOCAs from consideration using a leak-before-break argument. We can not presently accept this position. Leak-before-break evaluations were not intended for ECCS perfonnance evaluations. Although we have agreed to review leak-before-break evaluations by the Westinghouse Owners Group for mode 4 operation, we do not believe it appropriate to evaluate leak-before-break for mode 3 operation where reactor system pressure and temperatures would be much higher. Exclusion of double ended break sizes from the ECCS analysis would require a change in staff policy as well as an exemption from 10 CFR 50.46.

If you wish to obtain staff approval for operation in mode 3 with ECCS systems partially disabled as proposed, you must provide plant specific analysis of a complete break spectrum. The analyses must conform to, or be conservative in relation to the requirements of Appendix K to 10 CFR 50. Bounding calculations using reduced decay heat will be acceptable provided the minimum time after shutdown is specified in the proposed technical specification. In addition you should justify the operator action times that are assumed. If the isolated accumulator valve is assumed to open following a safety injection signal, you should justify that it would open against the differential pressures that would be encountered following a LOCA.

Sincer ly, fokspohkks00082 Paul . O'Connor Project Manager p PDR PWR Project Directorate #4 Division of PWR Licensing-A cc: See next page ,

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_i Mr. Bart D. Withers Wolf Creek Generating Station Wolf Creek Nuclear Operating Corporation Unit No. I 1

cc:

Mr. Gary L. Haden, Director Research & Energy Analysis Mr. Gary Boyer, Plant Manager Kansas Corporation Commission Wolf Creek Nuclear Operating Corp.

P.O. Box 411 4th Floor - State Office Building Burlington, Kansas 66839 Topeka, Kansas 66612-1571 Jay Silberg, Esq.

l Shaw, Pittman, Potts & Trowbridge Regional Administrator, Region IV 1800 M Street, NW U.S. Nuclear Regulatory Congnission Washington, D.C. 20036 Office of Executive Director for Operations l Chris R. Rogers, P.E. 611 Ryan Plaza Drive, Suite 1000 i

Manager, Electric Department Arlington, Texas 76011 Public Service Commission P. O. Box 360 l Jefferson City, Missouri 65102 Resident Inspector / Wolf Creek NPS c/o U.S. Nuclear Regulatory Consnission Regional Administrator, Region !!! P. O. Box 311 U.S. Nuclear Regulatory Commission Burlington, ransas 66C39 799 Roosevelt Road ,

Glen Ellyn, Illiroir 60137 Mr. Brian Moline Chief Legal Counsel Senior Resident inspector / Wolf Creek Vansas cercoration Consnission c/o U. S. Nuclear Reguletery Comission 4th Floor - State Office Building P. O. 3ox 311 Torefa, kansas 66612-1571 Burlintton, ransas 66839 Fr. RoLert Elliot, Chief Engf reer Mr. Otto Maynard, Manager Licensing Utilities Division Wolf Creek Nuclear Operating Corp.

Kansas Corporation Commission P. O. Box 411 4th Floor - State Office Building Burlington, Kansas 66839 Topeka, kansas 66612-1571 Mr. Gerald Allen Public Health Physicist Bureau of Air Ouality & Radiation Control Division of Environment kansas Department of Health and Environment Forbes Field Building 321 Topeka, Kansas 66620

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