ET 06-0024, Revision to Technical Specification 3.4.15, RCS Leakage Detection Instrumentation.

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Revision to Technical Specification 3.4.15, RCS Leakage Detection Instrumentation.
ML061860316
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 06/26/2006
From: Garrett T
Wolf Creek
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 06-0024
Download: ML061860316 (32)
v • d • e


Text

W LF CREEK 'NUCLEAR OPERATING CORPORATION Terry J Garrett Vice President, Engineering June 26, 2006 ET 06-0024 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 05-0007, dated August 26, 2005, from T. J. Garrett, WCNOC, to the NRC
2) Letter ET 05-0022, dated November 18, 2005, from T. J. Garrett, WCNOC, to the NRC
3) NRC letter dated May 16, 2006, from J. Donohew, NRC, to R. A. Muench, WCNOC

Subject:

Docket No. 50-482: Revision to Technical Specification 3.4.15, "RCS Leakage Detection Instrumentation" Gentlemen:

Reference 1) provided Wolf Creek Nuclear Operating Corporation's (WCNOC) application requesting approval of a change to the Reactor Coolant System (RCS) leak detection instrumentation system methodology. Reference 1) proposed to revise the Technical Specification (TS) Bases and the Updated Safety Analysis Report (USAR) to clarify the requirements of the containment atmosphere gaseous radioactivity monitor with regard to its RCS leak detection capability. Reference 2) provided responses to an electronic mail request for additional information. Reference 3) provided the Nuclear Regulatory Commission's (NRC's) position that the instrumentation listed in TS 3.4.15, "RCS Leakage Detection Instrumentation," as a method for meeting Part 50, Appendix A, General Design Criteria (GDC) 30 of Title 10 of the Code of Federal Regulation, should be capable of detecting 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 /> for realistic or normal plant conditions. Reference 3) requests that WCNOC either provide justification that the containment atmosphere gaseous radioactivity monitor can meet this position or revise Reference 1) to remove the gaseous radioactivity monitor from TS 3.4.15. Pursuant to 10 CFR 50.90, this submittal proposes to remove the gaseous radioactivity monitor from TS 3.4.15 and therefore, supersedes Reference 1) and Reference 2).

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

ET 06-0024 Page 2 The proposed changes to TS 3.4.15 are consistent with NUREG-1431, Revision 3.1, "Standard Technical Specifications Westinghouse Plants." Attachments I through V provide the Evaluation, Markup of Technical Specification Pages, Retyped Technical Specification Pages, Proposed TS Bases Changes (for information only), and List of Regulatory Commitments, respectively, in support of this amendment request. Final TS Bases changes will be implemented pursuant to TS 5.5.14, "Technical Specification Bases Control Program," at the time the amendment is implemented.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92. The amendment application was reviewed by the WCNOC Plant Safety Review Committee. In accordance with 10 CFR 50.91, a copy of this application is being provided to the designated Kansas State official.

WCNOC requests approval of this proposed license amendment by November 15, 2006. The changes proposed are not required to address an immediate safety concern. It is anticipated that the license amendment, as approved will be effective upon issuance, to be implemented within 90 days from the date of issuance. If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr. Kevin Moles at (620) 364-4126.

Vr rlyours, Terry J. Garrett TJG/rlt Attachments: I - Evaluation II - Markup of Technical Specification Pages III - Retyped Technical Specification Pages IV - Proposed TS Bases Changes (for information only)

V - List of Regulatory Commitments cc: T. A. Conley (KDHE), w/a J. N. Donohew (NRC), w/a W. B. Jones (NRC), w/a B. S. Mallett (NRC), w/a Senior Resident Inspector (NRC), w/a

STATE OF KANSAS )

) ss COUNTY OF COFFEY )

Terry J. Garrett, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering 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.

Terry J A;ra rrett Vice President Engineering SUBSCRIBED and sworn to before me this 2lday of ,Ji.UTI, 2006.

  • RHONDA L.TIEMEYER Notary Public fOFSCAL. . MY COMMISSION EXPIRES

.,,AL: .;*.. January 11, 2010 Expiration Date 0A2&A*~x)1&/L. c,0-A0/

U. a-" -

Attachment I to ET 06-0024 Page 1 of 8 EVALUATION

1.0 DESCRIPTION

This amendment application revises Technical Specification (TS) 3.4.15, "RCS Leakage Detection Instrumentation," to remove the containment atmosphere gaseous radioactivity monitor.

Evaluations have shown that the pre-existing containment radioactive gaseous background levels for which reliable detection is possible is dependent upon reactor power level, percent failed fuel, and containment purge operation. With primary coolant concentrations less than background equilibrium levels, such as during startup and operation with no fuel defects, the increase in detector count rate due to leakage will be partially masked by the statistical variation of the minimum detector background count rate, rendering reliable detection of a 1 gpm leak in one hour uncertain.

2.0 PROPOSED CHANGE

S Proposed TS 3.4.15 changes include:

  • Revised Limiting Condition for Operation (LCO) 3.4.15 to remove the containment atmosphere gaseous radioactivity monitor.
  • Revised Condition B Required Actions to provide an alternative to restoring the required containment atmosphere particulate radioactivity monitor to OPERABLE status. The alternative is the verification that the containment air cooler condensate monitoring system is OPERABLE.
  • Addition of new Condition C for required containment cooler condensate monitoring system inoperable. Existing Conditions C, D, and E are relettered.
  • Revised new Condition D to remove the containment atmosphere gaseous radioactivity monitor. Existing Required Actions C.1.1 and C.1.2 are deleted.

" Revised Surveillance Requirement (SR) 3.4.15.1, SR 3.4.15.2, and SR 3.4.15.4 to remove the containment atmosphere gaseous radioactivity monitor.

Proposed revisions to the TS Bases are also included in this application. The changes to the affected TS Bases pages will be incorporated in accordance with TS 5.5.14, "Technical Specifications (TS) Bases Control Program."

3.0 BACKGROUND

On November 9, 2004, the Nuclear Regulatory Commission (NRC) Integrated Inspection Report 05000482/2004004 issued noncited violation (NCV)05000482/2004004-001 (Reference

1) for failure to identify and correct a significant condition adverse to quality. In the report the NRC stated that the licensee failed to recognize that the containment atmosphere gaseous radioactivity monitors were inoperable. This issue had been previously entered into and

Attachment I to ET 06-0024 Page 2 of 8 evaluated under our corrective action program (Performance Improvement Request (PIR) 2003-1038). That evaluation determined that the containment atmosphere gaseous radioactivity monitors meet the design and licensing basis requirements in accordance with Regulatory Guide 1.45 (Reference 2), "Reactor Coolant Pressure Boundary Leakage Detection Systems," as documented in the Wolf Creek Generating Station (WCGS) Updated Safety Analysis Report (USAR). On November 17, 2004, Wolf Creek Nuclear Operating Corporation (WCNOC) conservatively declared the containment atmosphere gaseous radioactivity monitors inoperable for meeting LCO 3.4.15, pending resolution of this issue. Declaring the gaseous radioactivity monitors inoperable was based on the regulatory concern identified in the inspection report and ensuring compliance with LCO 3.4.15. The monitors were designed consistent with the guidance of Regulatory Guide 1.45 for having a sensitivity capable of detecting a 1 gpm leak in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> based on a primary coolant radioactivity concentration assumption utilized in the plant environmental report.

WCNOC submitted a license amendment request pursuant to criterion viii of 10 CFR 50.59(c)(2) on August 26, 2005 (Reference 3) that proposed changes to the TS Bases and USAR to clarify the requirements of the containment atmosphere gaseous radioactivity monitor with regard to its Reactor Coolant System (RCS) leak detection capability and provide clarification that the monitor can be considered OPERABLE (in compliance with LCO 3.4.15) during all applicable MODES even when reactor coolant radioactivity levels are below the levels assumed in the original licensing basis. On May 16, 2006 (Reference 4), the NRC provided a letter concerning the proposed amendment request that states, in part:

"It has always been the NRC's position that the instrumentation listed in TS 3.4.15 as a method for meeting Part 50, Appendix A, General Design Criterion (GDC) 30 of Title 10 of the Code of Federal Regulations, "Quality of reactor coolant pressure boundary,"

should be capable 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 realistic or normal plant conditions. In the NRC Standard Review Plan 5.2.5, "Reactor Coolant Pressure Boundary Leakage Detection," it is stated that RG 1.45 is an acceptable method to meet GDC 30 for RCS leak detection, and, in 1973, when RG 1.45 was issued, the underlying assumption was that the acceptable detection methods would have that detection capability for the normal plant conditions that existed at that time. The containment atmosphere gaseous radioactivity monitor was listed in RG 1.45 because the normal RCS radioactivity concentrations at that time were such that this monitor could detect 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 />. Now that normal plant conditions have much lower RCS radioactivity concentrations, the monitor cannot meet this criterion. Therefore, the RCS detection instrumentation in TS 3.4.15 should be capable of promptly detecting RCS leakage for the current plant conditions."

The NRC letter dated May 16, 2006 requested that WCNOC either provide justification that the containment atmosphere gaseous radioactivity monitor can meet the above criterion or revise the license amendment request to remove the monitor from TS 3.4.15. As identified in Reference 3, the containment gaseous radioactivity monitor cannot be assured to respond within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to a 1 gpm leak with low RCS activity levels. In addition, although low RCS activity levels have become the standard, there is a possibility that they may change. Predicting changing conditions and changing technical specifications is impractical. As such, WCNOC proposes to remove the gaseous radioactivity monitor from TS 3.4.15.

Attachment I to ET 06-0024 Page 3 of 8 Leak Detection System Design The diverse reactor coolant pressure boundary leakage detection system consists of the containment sump level and flow monitoring system, the containment air particulate monitoring system, the containment radioactive gas monitoring system, and the containment cooler condensate measuring system. The sump level and flow monitoring system indicates leakage by monitoring increases in sump level. The containment cooler condensate monitoring system detects leakage from the release of steam or water to the containment atmosphere. The air particulate and radioactive gas monitoring systems detect leakage from the release of radioactive materials to the containment atmosphere. OPERABILITY requirements for these systems are specified in the plant TSs. Each of these systems is described in further detail below.

In addition to the above systems, the containment humidity measuring system is also available as an indirect indication of leakage to the containment. Further, reactor coolant pressure boundary leakage can also be indicated by increasing charging pump flow rate compared with reactor coolant system inventory changes and by unscheduled increases in reactor makeup water usage.

CONTAINMENT SUMP LEVEL AND FLOW MONITORING SYSTEM - Since a leak in the primary system would result in reactor coolant flowing into the containment normal or instrument tunnel sumps, leakage would be indicated by a level increase in the sumps.

Indication of increasing sump level is transmitted from the sump to the control room level indicator by means of a sump level transmitter. The system provides measurements of low leakages by monitoring level increase versus time. A sensitivity of 1 gpm in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> can be achieved assuming that the water from the leak is collected in the sump.

The minimum detectable change in the containment normal sump level is 3 gallons and in the instrument tunnel sump level is 15 gallons. When the instrument tunnel sump is completely dry, the minimum detectable level change is 25 gallons. The levels are scanned by the Balance of Plant (BOP) computer once per minute, and the normal background rate of increase in sump level is subtracted to determine the leakage rate. The actual reactor coolant leakage rate can be established from the increase above the normal rate of change of sump level after consideration of 35 percent of the high temperature leakage which initially evaporates but may be condensed by the containment coolers and then is routed to the sump. A check of other instrumentation would be required to eliminate possible leakage from nonradioactive systems as a cause of an increase in sump level.

CONTAINMENT AIR PARTICULATE MONITOR - An air sample is drawn outside the containment into a closed system by a sample pump and is then consecutively passed through a particulate filter with detector, an iodine filter with detector, and a gaseous monitor chamber with detector. The particulate monitor has a range of 1012 to 10"7 pCi/cc and a minimum detectable concentration of 1011pCi/cc.

Particulate activity is determined from the containment free volume and the coolant fission and corrosion product particulate activity concentrations. Any increase of more than two standard deviations above the count rate for background would indicate a possible leak. The total particulate activity concentration above background, due to an abnormal leak and natural decay, increases almost linearly with time for the first several hours after the beginning of a leak. With 0.1-percent failed fuel, containment background airborne particulate radioactivity equivalent to 104 percent/day, and a partition factor equal to 0.2, a 1-gpm leak would be detected in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Attachment I to ET 06-0024 Page 4 of 8 CONTAINMENT COOLER CONDENSATE MONITORING SYSTEM - The condensate monitoring system permits measurements of the liquid runoff from the containment cooler units.

It consists of a containment cooler drain collection header, a vertical standpipe, valving, and standpipe level instrumentation for each cooler.

The condensate flow rate is a function of containment humidity, essential service water temperature leaving the coolers, and containment purge rate. The water vapor dispersed by a 1 gpm leak is much greater than the water vapor brought in with the outside air. Air brought in from the outside is heated to 50°F before it enters the containment.

After the air enters the containment, it is heated to 100-120 0 F so that the relative humidity drops. The water vapor brought in with the outside air does not build up in the containment.

Level changes of as little as 0.25 inches in the cooler condensate standpipes can be detected.

Increases in the condensation rates over normal background are monitored by the BOP computer based upon level checks each minute in order to determine the unidentified leakage.

A sensitivity of 1 gpm in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> can be achieved with cold essential service water temperature to the containment coolers or with initial background leakage.

CONTAINMENT GASEOUS RADIOACTIVITY MONITOR - The containment gaseous radioactivity monitor determines gaseous radioactivity in the containment by monitoring continuous air samples from the containment atmosphere. After passing through the gas monitor, the sample is returned via the closed system to the containment atmosphere. Each sample is continuously mixed in a fixed, shielded volume where its activity is monitored. The monitor has a range of 10-7 to 102pCi/cc and a minimum detectable concentration of 2 x 10.7 pCi/cc.

Gaseous radioactivity is determined from the containment free volume and the gaseous activity concentration of the reactor coolant. Any increase more than two standard deviations above the count rate for background would indicate a possible leak. The total gaseous activity level above background (after 1 year of normal operation) increases almost linearly for the first several hours after the beginning of the leak. With 0.1-percent failed fuel, containment background airborne gaseous radioactivity equivalent to 1 percent/day, and a partition factor equal to 1 (NUREG-0017 assumptions), a 1-gpm leak would be detected within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Need for the Amendment Although the detection capabilities of the containment gaseous radioactivity monitor are consistent with its design basis, the level of radioactivity in the reactor coolant at WCGS has become much lower than what is assumed in the original USAR analysis. As such, the containment atmosphere gaseous radioactivity monitors cannot be assured to respond within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to a 1 gpm leak with low RCS activity levels.

The NRC letter dated May 16, 2006 requested that WCNOC either provide justification that the containment atmosphere gaseous radioactivity monitor can meet the NRC position of 1 gpm in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> under normal plant conditions or revise the license amendment request to remove the monitor from TS 3.4.15. As identified in Reference 3, the containment gaseous radioactivity monitor will not respond within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to a 1 gpm leak with low RCS activity levels. As such, a license amendment is required for the removal of the gaseous radioactivity monitor from TS 3.4.15.

Attachment I to ET 06-0024 Page 5 of 8

4.0 TECHNICAL ANALYSIS

RCS leakage detection requirements are given in TS 3.4.15 which requires the following RCS leakage detection instrumentation to be OPERABLE:

a. The containment sump level and flow monitoring system;
b. One containment atmosphere particulate radioactive monitor; and
c. The containment cooler condensate monitoring system or one containment atmosphere gaseous radioactivity monitor.

The Bases for TS 3.4.15 state that GDC 30 of Appendix A to 10 CFR 50 requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE.

Regulatory Guide 1.45 describes acceptable methods for selecting leakage detection systems.

In addition the Bases discusses that leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure.

The detection of RCS leakage using radiation monitors is affected by the type and quantity of isotopes that are contained in the reactor coolant and the background level of radiation affecting/influencing the detectors. Regulatory Guide 1.45 guidance on analyzing the sensitivity of radiation monitors used for RCS leakage detection recommends that a realistic primary coolant radioactivity concentration assumption be used. The Regulatory Guide further defines the realistic primary coolant concentration as the values used in the plant environmental report.

For WCGS these concentration values are based on a 0.12% fuel defect from the WCGS Environmental Report - Operating Licensing Stage (Reference 5). With the level of radioactivity in the reactor coolant assumed in the WCGS Environmental Report - Operating Licensing Stage, the containment atmosphere particulate and gaseous radioactivity detectors are capable of detecting a one gpm leak in one hour. However, operational history of the plant has shown the level of radioactivity in the reactor coolant with no fuel defects is much lower than what is assumed in the USAR. The regulatory guide acknowledges the limitations of radiation monitoring for leak detection when the RCS activity is low. Further, the regulatory guide recommends a sensitivity of 1 x 106 for gaseous radioactivity monitors used for leak detection.

The existing containment atmosphere gaseous radioactivity channel has a sensitivity of 2 x 10"7 and a range of 10"7 to 10-2 pCi/cc, which meets the criteria specified in Regulatory Guide 1.45.

Given the current level of radioactivity in the reactor coolant at WCGS with no or minor fuel cladding defects, evaluation has shown that the containment atmosphere gaseous radioactivity monitors would not promptly detect a one gpm leak in one hour. This conclusion is based on a realistic nominal detector background level, with the typical RCS gaseous activity associated with no fuel cladding defects. For these lower RCS activity levels, the increase in detector count rate due to leakage will be partially masked by 1) the statistical variation of the minimum detector background count rate, and 2) the Ar-41 activation activity rendering reliable detection of a 1 gpm leak in one hour uncertain. At elevated RCS activity/failed fuel conditions as discussed in Regulatory Guide 1.45, a one gpm leak would be detectable within one hour, even at higher detector background.

Regulatory Guide 1.45, Section B, discusses the selection of diverse leak detection methods given that the methods differ in sensitivity and response time. Prudent selection of detection methods should include sufficient systems to assure effective monitoring during periods when some detection systems may be ineffective or inoperable.

Attachment I to ET 06-0024 Page 6 of 8 The proposed changes to TS 3.4.15 are consistent with NUREG-1431, Revision 3.1, "Standard Technical Specifications Westinghouse Plants." Condition B is revised to add a new Required Action to provide an alternative to restoring the required containment atmosphere particulate radioactivity monitor to OPERABLE status. The alternative is the verification that the containment air cooler condensate monitoring system is OPERABLE. This change is acceptable based on the containment air cooler condensate monitoring system providing indication of leakage together with either grab samples of containment atmosphere or performance of water inventory balance in accordance with SR 3.4.13.1 that will provide information adequate for leak detection. With the deletion of the containment atmosphere gaseous radioactivity monitor from the LCO and Conditions, a new Condition C is added for the required containment cooler condensate system being inoperable. The Required Actions for new Condition C require the performance of SR 3.4.15.1 or a water inventory balance in accordance with SR 3.4.13.1. The Required Action to perform a CHANNEL CHECK or water inventory balance is acceptable based on the availability of other diverse means to detect leakage and the impracticality of containment entries at power for repairs.

With the removal of the containment atmosphere gaseous radioactivity monitor from TS 3.4.15, the remaining leakage detection system will provide adequate capability to promptly detect RCS leakage.

5.0 REGULATORY ANALYSIS

5.1 NO SIGNIFICANT HAZARDS CONSIDERATION This amendment application revises Technical Specification (TS) 3.4.15, "RCS Leakage Detection Instrumentation," to remove the containment atmosphere gaseous radioactivity monitor.

WCNOC has evaluated the proposed change and determined that the change does not involve a significant hazards consideration for WCGS based on the three standards set forth in 10 CFR 50.92(c) as discussed below:

(1) The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Response: No The proposed change has been evaluated and determined to not increase the probability or consequences of an accident previously evaluated. The proposed change does not make any hardware changes and does not alter the configuration of any plant system, structure, or component (SSC). The proposed change only removes the containment atmosphere gaseous radioactivity monitor as an option for meeting the OPERABILITY requirements for TS 3.4.15.

The TS will continue to require diverse means of leakage detection equipment, thus ensuring that leakage due to cracks would continue to be identified prior to propagating to the point of a pipe break and the plant shutdown accordingly. Therefore, the consequences of an accident are not increased.

Attachment I to ET 06-0024 Page 7 of 8 (2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Response: No The proposed change does not involve the use or installation of new equipment and the currently installed equipment will not be operated in a new or different manner, No new or different system interactions are created and no new processes are introduced. The proposed changes will not introduce any new failure mechanisms, malfunctions, or accident initiators not already considered in the design and licensing bases. The proposed change does not affect any SSC associated with an accident initiator. Based on this evaluation, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) The proposed change does not involve a significant reduction in a margin of safety.

The proposed change does not alter any Reactor Coolant System (RCS) leakage detection components. The proposed change only removes the containment atmosphere gaseous radioactivity monitor as an option for meeting the OPERABILITY requirements for TS 3.4.15.

This change is required since the level of radioactivity in the WCGS reactor coolant has become much lower than what was assumed in the USAR and the gaseous channel can no longer promptly detect a small RCS leak under normal conditions. The proposed amendment continues to require diverse means of leakage detection equipment with capability to promptly detect RCS. leakage. Although not required by TS, additional diverse means of leakage detection capability are available as described in the Updated Safety Analysis Report Section 5.2.5. Early detection of leakage, as the potential indicator of a crack(s) in the RCS pressure boundary, will thus continue to be in place so that such a condition is known and appropriate actions taken well before any such crack would propagate to a more severe condition. Based on this evaluation, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, WCNOC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion 30, "Quality of reactor coolant pressure boundary," requires that means be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.

The various means for detecting reactor coolant leakage at WCGS were previously discussed in Section 3.0, "Background."

As described in the USAR, the WCGS design conforms to Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," dated May 1973. Regulatory Guide 1.45 describes acceptable methods for implementing the requirement of Criterion 30 (above) with regard to the selection of leakage detection systems for the reactor coolant pressure boundary. The specific attributes of the reactor coolant leakage detection systems are outlined in Regulatory Position 1 through 9 of Regulatory Guide 1.45. WCGS conformance with Regulatory Guide 1.45 is described in Appendix 3A and USAR Table 5.2-6. Removal of the

Attachment I to ET 06-0024 Page 8 of 8 containment atmosphere gaseous radioactivity monitor from the TS is not in conflict with the guidance of the Regulatory Guide and will result in conformance with the NRC position provided in Reference 4.

10 CFR 50.36, 'Technical Specifications," paragraph (c)(2)(ii)(A), specifies that a TS limiting condition for operation of a nuclear reactor must be established for installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Currently, the instrumentation addressed in TS 3.4.15 satisfies this requirement. The removal of the containment atmosphere gaseous radioactivity monitor from the TS is not in conflict with this requirement.

There will be no changes .such that compliance with any of the regulatory requirements and guidance documents above would come into question. The evaluations performed by WCNOC confirm that WCGS will continue to comply with all applicable regulatory requirements.

6.0 ENVIRONMENTAL CONSIDERATION

WCNOC has determined that the proposed amendment would change requirements with respect to the installation or use of.a.facility component located within the restricted area, as defined'in 10 CFR 20, or would change an inspection or surveillance requirement. However, WCNOC has evaluated the proposed amendment and has determined-that the amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase. inthp individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22 (b), an environmental assessment of the proposed amendment is not required.

7.0 REFERENCES

1) NRC Integrated Inspection Report 05000482/2004004, November 9, 2004.
2) Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973.
3) WCNOC letter ET 05-0007, "Request for Approval of Changes to the Reactor Coolant System Leakage Detection Instrumentation Methodology, August 26, 2005.
4) NRC letter, 'Wolf Creek Generating Station - License Amendment Request to Change the Reactor Coolant System Leakage Detection Instrumentation Methodology (TAC NO.

MC8214)," May 16, 2006.

5) WCGS Environmental Report - Operating Licensing Stage (letter KMLNRC-023 dated August 19, 1980.)

Attachment II to ET 06-0024 Page 1 of 6 ATTACHMENT II MARKUP OF TECHNICAL SPECIFICATION PAGES

Attachment II to ET 06-0024 Page 2 of 6 RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. The containment sump level and flow monitoring System;
b. One containment atmosphere particulate radioactivity monitor; and
c. One containment air cooler condensate monitoring system*

ctai e at sph g ous d,otivim APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS I CONDITION REQUIRED ACTION COMPLETIONTIME A. Required containment A.1 --------- NOTE-------

sump level and flow Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> monitoring system after establishment of inoperable. steady state operation.

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 /> AND A.2 Restore required 30 days containment sump level and flow monitoring system to OPERABLE status.

(continued)

Wolf Creek - Unit 1 3.4-37 Amendment No. 4-2-, 155

Attachment II to ET 06-0024 Page 3 of 6 RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required containment B.1.1 Analyze samples of the Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> atmosphere particulate containment atmosphere.

radioactivity monitor inoperable. OR B.1.2 Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

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 /> AND

.2 -Restore required 30 days containment atmosphere particulate radioactivity monitor to OPERABLE status.

(continued)

', 5ys,,- I Wolf Creek - Unit I 3.4-38 Amendment No. 123

Attachment II to ET 06-0024 Page 4 of 6 INSERT 3.4-48 C. Required containment C.1 Perform 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 /> cooler condensate monitoring system OR inoperable.

C.2 NOTE------- -----

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

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 />

Attachment II to ET 06-0024 Page 5 of 6 RCS Leakage Detection Instrumentation 3.4.15

  • Required containment D atmosphere&W**

radioactivity monitor inoperable.

AND Required containment cooler condensate monitoring system inoperable.

Restore required 30 days containment atmosphere g radioactivity monitor to OPERABLE status.

Restore required 30 days containment cooler condensate monitoring system to OPERABLE status.

2Required 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 />

'associated Completion Time not met.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

Wolf Creek - Unit 1 3.4-39 Amendment No. 123

Attachment II to ET 06-0024 Page 6 of 6 RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION I REQUIRED ACTION COMPLETION TIME All required monitoring Enter LCO 3.0.3. Immediately methods inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> containment atmosphg.e particulate(a._ 9 radioactivity monitorg.

SR 3.4.15.2 Perform COT of the required containment 92 days atmosphere particulate 6radioactivity monitort'-

SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required 18 months containment sump level and flow monitoring system.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of the required 18 months containment atmosphere particulate radioactivity monitorr SR 3.4.15.5 Perform CHANNEL CALIBRATION of the required 18 months containment cooler condensate monitoring system.

Wolf Creek - Unit 1 3.4-40 Amendment No. 123

Attachment III to ET 06-0024 Page 1 of 3 ATTACHMENT III RETYPED TECHNICAL SPECIFICATION PAGES

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. The containment sump level and flow monitoring system;
b. One containment atmosphere particulate radioactivity monitor; and
c. One containment air cooler condensate monitoring system.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required containment A.1 NOTE----

sump level and flow Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> monitoring system after establishment of inoperable, steady state operation.

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 /> AND A.2 Restore required 30 days containment sump level and flow monitoring system to OPERABLE status.

(continued)

Wolf Creek - Unit 1 3.4-37 Amendment No. 1-23* 45,

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required containment B.1.1 Analyze samples of the Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> atmosphere particulate containment atmosphere.

radioactivity monitor inoperable. OR B.1.2 NOTE Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

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 /> AND B.2.1 Restore required 30 days containment atmosphere particulate radioactivity monitor to OPERABLE status.

OR B.2.2 Verify containment air 30 days cooler condensate monitoring system is OPERABLE.

C. Required containment C.1 Perform 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 /> cooler condensate monitoring system OR inoperable.

C.2 NOTE Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

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 />

___________________________________ L ______________________________________ L (continued)

Wolf Creek - Unit 1 3.4-38 Amendment No. 42-3,

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required containment D.1 Restore required 30 days atmosphere particulate containment atmosphere radioactivity monitor particulate radioactivity inoperable, monitor to OPERABLE status.

AND OR Required containment cooler condensate D.2 Restore required 30 days monitoring system containment cooler inoperable, condensate monitoring system to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND E.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> F. All required monitoring F.1 Enter LCO 3.0.3. Immediately methods inoperable.

Wolf Creek - Unit 1 3.4-39 Amendment No. 423,

RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> containment atmosphere particulate radioactivity monitor.

SR 3.4.15.2 Perform COT of the required containment 92 days atmosphere particulate radioactivity monitor. I SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required 18 months containment sump level and flow monitoring system.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of the required 18 months containment atmosphere particulate radioactivity monitor.

SR 3.4.15.5 Perform CHANNEL CALIBRATION of the required 18 months containment cooler condensate monitoring system.

Wolf Creek - Unit 1 3.4-40 Amendment No. 423,

Attachment IVto ET 06-0024 Page 1 of 9 ATIACHMENT IV PROPOSED TS BASES CHANGES (for information only)

Attachment IVto ET 06-0024 Page 2 of 9 RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE.

Industry practice has shown that water flow changes of 0.5,to 1.0 gpm can be readily detected in contained volumes by monitoring changes in water level, in flow rate, or in the operating frequency of a pump (Ref. 2).

The Containment Sump Level and Flow Monitoring System used to collect unidentified LEAKAGE and Containment Cooler Condenspte Monitoring System are instrumented to alarm for increases of 0.5 to 1.0 gpm in the normal flow rates. The instrumentation provided is such that over a period of time (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or more), the collected flow rate can be determined with an accuracy of better than 1.0 gpm (Ref. 3). This sensitivity is acceptable for detecting increases in unidentified LEAKAGE.

The reactor coolant contains radioactivity that, when released to the containment, can be detected by radiation monitoring instrumentation.

Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. Instrument sensitivities of i0 Ci/cc radioactivity for particulate monitoring &T@1__wrc 2!.*fi" mboitt!rfare practical for leaka e detection s sterrh.

Radioactivity..etection systems (GT RE-32) are included for monitoring '.particulate because of their sensitivities and rapid responses to RCS LEAKAGE. .  : )j "AAn increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE. A 1OF increase in dew point is well within the sensitivity range of available instruments.

Wolf Creek - Unit 1 .B 3.4.15-1 Revision 2

Attachment IVto ET 06-0024 Page 3 of 9 INSERT B 3.4.15-1 The measurement of containment atmosphere gaseous radioactivity is less sensitive than the measurement of particulate radioactivity for the purpose of detecting RCS leakage. Evaluations have shown that the pre-existing containment radioactive gaseous background levels for which reliable detection is possible is dependent upon the reactor power level, percent failed fuel in the reactor, and air volume exchange brought about by the containment purge system. With primary coolant radionuclide concentrations less than equilibrium levels, such as during startup and operation with no fuel defects, the increase in detector count rate due to leakage will be partially masked by 1) the statistical variation of the minimum detector background count rate, and 2) the Ar-41 activation activity rendering reliable detection of a 1 gpm leak uncertain. The containment gaseous radioactivity monitor is considered most useful for detecting an RCS-to-containment atmosphere leak if elevated reactor coolant gaseous activity is present. The containment gaseous radioactivity monitors are not required by this LCO. (Reference 8)

Attachment IV to ET 06-0024 Page 4 of 9 RCS Leakage Detection Instrumentation B 3.4.15 BASES APPLICABLE locations are utilized, if needed, to ensure that the transport delay time of SAFETY ANALYSES the leakage from its source to an instrument location yields an acceptable (continued) overall response time.

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leak occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii).

LCO One method of protecting against large RCS leakage derives from the ability of instruments to rapidly detect extremely small leaks..This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the Containment Sump Level and Flow Monitoring System, one containment atmosphere particulate radioactivity monitor and 65athe Containment Cooler Condensate Flow Monitoring System c-ta rt at*iosere gfseo),* roatrvIfynnit, provide an acceptable minimum.

For containment atmosphere*,o*'*dparticulate radioactivity monitor instrumentation, OPERABILITY -invovyes more than OPERABILITY of the channel electronics. OPERABILITY also reguires correct valve lineups, sample pump operation,"-,,r)6 aitl*ti ,*rb'rifs sample line insulation and heat tracing, as well as detector OPERABILITY, since these supporting features are necessary for the monitors to rapidly detect RCS LEAKAGE.

The Containment Cooler Condensate Flow Monitoring System is considered OPERABLE when it is capable of measuring liquid flow from the containment coolers. An OPERABLE Containment Cooler Condensate Flow Monitoring System consists of a containment cooler drain collection header, a vertical standpipe, valving, and standpipe level indication for each cooler. Additionally, the plant process computer must be capable of calculating the leakage rate indicated by the condensate being collected. At least two containment coolers must be operating for the Containment Cooler Condensate Flow Monitoring System to be OPERABLE (Ref. 6).

Wolf Creek - Unit 1 B 3.4.15-3 Revision 24

Attachment IVto ET 06-0024 Page 5 of 9 RCS Leakage Detection Instrumentation B 3.4.15 BASES LCO Each containment cooler's air inlet temperature, relative humidity and dew (continued) point determines the amount of condensate the cooler will produce.

Historically, the "D"containment cooler has produced the least amount of condensate. A containment cooler that is producing a small amount of condensate may result in a stable standpipe level and infrequent attuation of the automatic dump valve. Indications that the automatic dump valve may not be operating properly are no level indication in the standpipe or overfilling of the containment cooling drip pan (Ref. 7).

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 31 and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is required to be < 200OF and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A.1 and A.2 A primary system leak would result in reactor coolant flowing into the containment normal sumps or into the instrument tunnel sump. Indication of increasing sump level is transmitted to the control room by means of individual sump level transmitters. This information is used to provide measurement of low leakage by monitoring level increase versus time.

With the required Containment Sump Level and Flow Monitoring System inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere particulate radioactivity monitor will provide indications of changes in leakage.

Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation IaRg.reuu table RCS pressure, t-mperature, power level, pressurizer and makeup tank level, makeup and letdown, and RCP seal injection and return flows). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Wolf Creek - Unit 1 B 3.4.15-4 Revision 24

Attachment IVto ET 06-0024 Page 6 of 9 RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS A.1 and A.2 (continued)

Restoration of the required Containment Sump Level and Flow Monitoring System to OPERABLE status within a Completion Time of 30 days is required to regain the function after the system's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance required by Required Action A.1.

With the containment atmosphere particulate radioactivity monitoring instrumentation channel inoperable, alternative action is required. Either samples of the containment atmosphere must be taken and analyzed for pg A articulate radioactivity or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere particulate radioactivity monitor.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (ar.q l; r.i *. M. stable RCS pressure, temperature, power level, pressurizer and makeup tank level, makeup and letdown, and RCP seal injection and return flows). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. The 30 day Completion Time recognizes at least one other form of leakage detection is available.

With the required containment atmosphere radioactivity monitor and the required Containment Cooler Condensa4eMonitoring System inoperable, the means of detecting leakage ithe Containment Sump Level and Flow Monitoring S t -qe t . e This Condition does not provide all the required diverse means of leakage detection. ithhe con mine atmo here r-dioactivit*noni orl 'g and ontain ýent Coer Co ensate M ritoringstem in rument ion ch nels in erable, alter tive acti n re;qr. Eer mp the c tainme atmo here ust be .en and a d pa ulate dioacti ity or ter inv tory Wolf Creek - Unit 1 B 3.4.15-5 Revision 24 1

f Attachment IVto ET 06-0024 Page 7 of 9 INSERT B 3.4.15-5A Alternatively, continued operation is allowed if the containment air cooler condensate monitoring system is OPERABLE, provided grab samples are taken or water inventory balances are performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

INSERT B 3.4.15-5B C.1 and C.2 With the required containment cooler condensate monitoring system inoperable, alternative action is again required. Either SR 3.4.15.1 must be performed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

Provided a CHANNEL CHECK is performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or a water inventory balance is performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, reactor operation may continue while awaiting restoration of the containment cooler condensate monitoring system to OPERABLE status.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect RCS LEAKAGE. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeup tank level, makeup and letdown, and RCP seal injection and return flows.) The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Attachment IV to ET 06-0024 Page 8 of 9 RCS Leakage Detection Instrumentation B 3.4.15 ACTIONS ý .2 dontinued) bala es, in cordan with SR 3 .13.1, st be pe ormed to/lOrovide al mate priodic inf rmation. ote is a ded allo g that S 3.4.13 not re uired to performe until 12 urs after stablishiyg stead state peration ear opera g rated erating essure stabl CS pr sure,te erature, erlevel ressur r and ma up ta level, akeup a letdown, d RCP s al inet nd ret n flow . The7 hour al neorlle ~filttect ar~ proces I nece aet data a r stable nt c r tablish d. The 4 Required Action is to restore either of the inoperable required monitoring methods to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a reduced configuration for a lengthy time period.

Refer to LCO 3.3.6, "Containment Purge Isolation Instrumentation," upon' a loss of the required containment atmosphere radioactivity monitor to ensure LCO requirements are met.

Fn . m , "

If a Required Action of Condition A, Bot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and

'without challenging plant systems.

With all required monitoring methods inoperable, no automatic'means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required gontainment atmosphere particulate Q ýRagjoradioactivity monitoe. The check gives reasonable confidence that the channel ) -t.

operating properly. The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on instrument' reliability and is reasonable for detecting off normal conditions.

Wolf Creek - Unit 1 B 3.4.15-6 Revision 24 1

Attachment IVto ET 06-0024 Page 9 of 9 RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE SR 3.4.15.2 REQUIREMENTS (continued) SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere particulate 7 radioactivity monitor.

The test ensures that the monitort'can performn *function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.3, SR 3.4.15.4, and SR '3.4.15.5 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is atypical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable REFERENCES 1. 10 CFR 50, Appendix A, Section IV, GDC 30.

2. Regulatory.Guide 1.45.
3. USAR, Section 5.2.5.
4. NUREG-609, "Asymmetric Blowdown Loads on PWR Primary Systems," 1981.
5. Generic Letter 84-04, "Safety Evaluation of Westinghouse Topical Reports Dealing with Elimination of Postulated Pipe Breaks in PWR Primary Main Loops."
6. USAR, Section 6.2.2.2.2. I I

,'-p.- 7. Performance Improvement Request 2005-2823.

S y5*ebri LeA3k& 5'e 1WDkltGttn 1nteWNtfeC~n*dior tAC#U&1a%

Wolf Creek - Unit 1 B 3.4.15-7 Revision 24

Attachment V to ET 06-0024 Page 1 of I LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by WCNOC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Kevin Moles at (620) 364-4126.

COMMITMENT Due DatelEvent The license amendment will be implemented within 90 days of Within 90 days of issuance. Final TS Bases changes will be implemented NRC issuance pursuant to TS 5.5.14 at the time the amendment is implemented.

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