ML22353A555

Application to Revise Technical Specifications to Adopt TSTF-554-A, Revision 1, Revise Reactor Coolant Leakage Requirements

ML22353A555
Person / Time
Site:	Wolf Creek
Issue date:	12/15/2022
From:	Boyce M Wolf Creek
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
22-0015, TSTF-554-A, Rev 1
Download: ML22353A555 (1)

Text

Michael T. Boyce Vice President Engineering December 15, 2022 ET 22-0015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: Application to Revise Technical Specifications to Adopt TSTF-554-A, Revision 1, Revise Reactor Coolant Leakage Requirements Commissioners and Staff:

In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Wolf Creek Nuclear Operating Corporation (WCNOC) is submitting a request for an amendment to the Technical Specifications (TS) for the Wolf Creek Generating Station (WCGS).

WCNOC requests adoption of Technical Specifications Task Force (TSTF)-554-A, Revise Reactor Coolant Leakage Requirements, which is an approved change to the Standard Technical Specifications (STS), into the WCGS TS. The proposed amendment revises the TS definition of LEAKAGE, clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified. The change is requested as part of the Consolidated Line Item Improvement Process (CLIIP).

Attachment I provides a description and assessment of the proposed changes. Attachment II provides the existing TS pages marked to show the proposed changes. Attachment III provides revised (clean) TS pages. Attachment IV provides existing TS Bases pages marked to show the proposed changes for information only.

Approval of the proposed amendment is requested within 12 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 60 days.

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831

ET 22-0015 Page 2 of 3 In accordance with 10 CFR 50.91, Notice for public comment; State consultation, Section (b)(1),

a copy of this application, with Attachments, is being provided to the designated Kansas State official.

The letter contains no new regulatory commitments. If you have any questions concerning this matter, please contact me at (620) 364-8831 x8687, or Dustin Hamman at (620) 364-4204.

Sincerely, Michael T. Boyce MTB/jkt Attachment I Evaluation of Proposed Change Attachment II Proposed Technical Specification Changes (Mark-Up)

Attachment III Revised Technical Specification Pages Attachment IV Proposed Technical Specification Bases Changes (Mark-Up) for Information Only cc: S. S. Lee (NRC), w/a S. A. Morris, (NRC), w/a K. S. Steves (KDHE), w/a G. E. Werner (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 22-0015 Page 3 of 3 STATE OF KANSAS )

) ss COUNTY OF COFFEY )

Michael T. Boyce, 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.

By:

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Michael T. Boyce Vice President Engineering SUBSCRIBED and sworn to before me this \ £:', d y of , 2022.

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Expiration Date

Attachment I to ET 22-0015 Page 1 of 4 EVALUATION OF PROPOSED CHANGE

Subject:

Application to Revise Technical Specifications to Adopt TSTF-554-A, Revision 1, Revise Reactor Coolant Leakage Requirements

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion

4.0 ENVIRONMENTAL CONSIDERATION

Attachment I to ET 22-0015 Page 2 of 4

1.0 DESCRIPTION

Wolf Creek Nuclear Operating Corporation (WCNOC) requests adoption of Technical Specification Task Force (TSTF)-554-A, Revision 1, Revise Reactor Coolant Leakage Requirements, which is an approved change to the Standard Technical Specifications (STS),

into the Wolf Creek Generating Station (WCGS) Technical Specifications (TS). The proposed amendment revises the TS definition of LEAKAGE, clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified.

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation WCNOC has reviewed the safety evaluation for TSTF-554, Revision 1, provided to the Technical Specifications Task Force in a letter dated December 18, 2020. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-554-A. As described herein, WCNOC has concluded that the justifications presented in TSTF-554-A and the safety evaluation prepared by the NRC staff are applicable to WCGS and justify this amendment for the incorporation of the changes into the WCGS TS.

2.2 Optional Changes and Variations WCNOC is not proposing any variations from the TS changes described in TSTF-554-A, Revision 1, or the applicable parts of the NRC staffs safety evaluation dated December 18, 2020.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Wolf Creek Nuclear Operating Corporation (WCNOC) requests adoption of TSTF-554-A, Revision 1, Revise Reactor Coolant Leakage Requirements, that is an approved change to the Standard Technical Specifications (STS), into the Wolf Creek Generating Station (WCGS) Technical Specifications (TS). The proposed amendment revises the TS definition of LEAKAGE, clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified.

WCNOC has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed amendment revises the TS definition of LEAKAGE, clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified.

Attachment I to ET 22-0015 Page 3 of 4 The proposed change revises the definition of pressure boundary leakage. Pressure boundary leakage is a precursor to some accidents previously evaluated. The proposed change expands the definition of pressure boundary leakage by eliminating the qualification that pressure boundary leakage must be from a nonisolable flaw. A new TS Required Action is created which requires isolation of the pressure boundary flaw from the Reactor Coolant System (RCS). This new action provides assurance that the flaw will not result in any accident previously evaluated.

Pressure boundary leakage, and the actions taken when pressure boundary leakage is detected, is not assumed in the mitigation of any accident previously evaluated. As a result, the consequences of any accident previously evaluated are unaffected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed amendment revises the TS definition of LEAKAGE, clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified. The proposed change does not alter the design function or operation of the RCS. The proposed change does not alter the ability of the RCS to perform its design function. Since pressure boundary leakage is an evaluated accident, the proposed change does not create any new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed amendment revises the TS definition of LEAKAGE, clarifies the requirements when pressure boundary leakage is detected, and adds a Required Action when pressure boundary leakage is identified. The proposed change does not affect the initial assumptions, margins, or controlling values used in any accident analysis. The amount of leakage allowed from the RCS is not increased. The proposed change does not affect any design basis or safety limit or any Limiting Condition for Operation.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, WCNOC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

Attachment I to ET 22-0015 Page 4 of 4 3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to 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, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Attachment II to ET 22-0015 Page 1 of 5 ATTACHMENT II PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Attachment II to ET 22-0015 Page 2 of 5 Definitions 1.1 1.1 Definitions (continued)

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-87, Kr-88, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity.

The determination of DOSE EQUIVALENT XE-133 shall be performed using the effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its ESF actuation TIME setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank;

2. LEAKAGE into the containment atmosphere from to sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE; or (continued)

Wolf Creek - Unit 1 1.1-3 Amendment No. 123, 131, 170, 221

Attachment II to ET 22-0015 Page 3 of 5 Definitions 1.1 1.1 Definitions (continued)

LEAKAGE 3. Reactor Coolant System (RCS) LEAKAGE (continued) through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b. Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE;

c. Pressure Boundary LEAKAGE LEAKAGE past seals, packing, and gaskets is not pressure LEAKAGE (except primary to secondary LEAKAGE) boundary LEAKAGE. through a nonisolable fault in an RCS component body, pipe wall, or vessel wall.

MASTER RELAY TEST A MASTER RELAY TEST shall consist of energizing all master relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required master relay. The MASTER RELAY TEST shall include a continuity check of each associated required slave relay. The MASTER RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

MODE A MODE shall correspond to any one inclusive combination of core reactivity condition, power level, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE--OPERABILITY A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:

a. Described in Chapter 14, of the USAR;

b. Authorized under the provisions of 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Regulatory Commission.

(continued)

Wolf Creek - Unit 1 1.1-4 Amendment No. 123, 164, 170, 221

Attachment II to ET 22-0015 Page 4 of 5 RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a. No pressure boundary LEAKAGE;

b. 1 gpm unidentified LEAKAGE;

c. 10 gpm identified LEAKAGE; and

d. 150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME INSERT 3.4-32 A. RCS operational A.1 Reduce LEAKAGE to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> LEAKAGE not within limits within limits.

for reasons other than B. pressure boundary B.1 LEAKAGE or primary to secondary LEAKAGE.

C.1 B. Required Action and B.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 of Condition A not AND C.2 C. met.

B.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 /> OR Pressure boundary LEAKAGE exists.

OR Primary to secondary LEAKAGE not within limit.

Wolf Creek - Unit 1 3.4-32 Amendment No. 123, 164, 212

Attachment II to ET 22-0015 Page 5 of 5 INSERT 3.4-32 A. Pressure boundary A.1 Isolate affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> LEAKAGE exists. component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve.

Attachment III to ET 22-0015 Page 1 of 5 ATTACHMENT III REVISED TECHNICAL SPECIFICATION PAGES

Definitions 1.1 1.1 Definitions (continued)

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-87, Kr-88, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using the effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its ESF actuation TIME setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff); that is captured and conducted to collection systems or a sump or collecting tank;

2. LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or

3. Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

(continued)

Wolf Creek - Unit 1 1.1-3 Amendment No. 123, 131, 170, 221,

Definitions 1.1 1.1 Definitions (continued)

LEAKAGE b. Unidentified LEAKAGE (continued)

All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE;

c. Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

MASTER RELAY TEST A MASTER RELAY TEST shall consist of energizing all master relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required master relay. The MASTER RELAY TEST shall include a continuity check of each associated required slave relay. The MASTER RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

MODE A MODE shall correspond to any one inclusive combination of core reactivity condition, power level, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE--OPERABILITY A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:

a. Described in Chapter 14, of the USAR;

b. Authorized under the provisions of 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Regulatory Commission.

(continued)

Wolf Creek - Unit 1 1.1-4 Amendment No. 123, 164, 170, 221,

RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a. No pressure boundary LEAKAGE;

b. 1 gpm unidentified LEAKAGE;

c. 10 gpm identified LEAKAGE; and

d. 150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressure boundary A.1 Isolate affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> LEAKAGE exits. component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve.

B. RCS operational B.1 Reduce LEAKAGE to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> LEAKAGE not within limits within limits.

for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

(continued)

Wolf Creek - Unit 1 3.4-32 Amendment No. 123, 164, 212,

RCS Operational LEAKAGE 3.4.13 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 OR C.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 /> Primary to secondary LEAKAGE not within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 -----------------------------NOTES-------------------------------

1. 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 establishment of steady state operation.

2. Not applicable to primary to secondary LEAKAGE.

Verify RCS operational LEAKAGE is within limits by In accordance with performance of RCS water inventory balance. the Surveillance Frequency Control Program SR 3.4.13.2 -----------------------------NOTE---------------------------------

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 establishment of steady state operation.

Verify primary to secondary LEAKAGE is 150 In accordance with gallons per day through any one SG. the Surveillance Frequency Control Program Wolf Creek - Unit 1 3.4-33 Amendment No. 123, 164, 212, 227,

Attachment IV to ET 22-0015 Page 1 of 6 ATTACHMENT IV PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP) FOR INFORMATION ONLY

Attachment IV to ET 22-0015 Page 2 of 6 RCS Operational LEAKAGE B 3.4.13 BASES APPLICABLE Except for primary to secondary LEAKAGE, the safety analyses do not SAFETY ANALYSES address RCS operational LEAKAGE. However, the other forms of operational LEAKAGE are related to the safety analyses for LOCA; the amount of leakage can affect the probability of such an event. The safety analyses for events resulting in steam discharge to the atmosphere assume that primary to secondary LEAKAGE from all steam generators (SGs) is one gallon per minute as a result of accident induced conditions.

The LCO requirement to limit primary to secondary LEAKAGE through any one SG to less than or equal to 150 gallons per day is significantly less than the conditions assumed in the safety analysis.

Primary to secondary LEAKAGE is a factor in the dose releases outside containment resulting from a steam line break (SLB) accident. Other accidents or transients involving secondary steam release to the atmosphere, include the steam generator tube rupture (SGTR). The leakage contaminates the secondary fluid.

The USAR (Ref. 3) analysis for SGTR assumes some of the contaminated secondary fluid is released via atmospheric relief valves.

The safety analysis for the SLB accident assumes the entire 1 gpm primary to secondary LEAKAGE is through the affected generator as an initial condition. The dose consequences resulting from the SLB and accidents involving secondary steam release to the atmosphere are within the limits defined in 10 CFR 50.67 (Ref. 5) and the Standard Review Plan (Ref. 8).

The safety analysis for RCS main loop piping for GDC-4 (Ref. 1) assumes 1 gpm unidentified leakage and monitoring per Regulatory Guide 1.45 (Ref. 2) are maintained (Ref. 4).

The RCS operational LEAKAGE satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO RCS operational LEAKAGE shall be limited to:

prohibited

a. Pressure Boundary LEAKAGE No pressure boundary LEAKAGE is allowed, being indicative of material deterioration. LEAKAGE of this type is unacceptable as RCPB the leak itself could cause further deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

Wolf Creek - Unit 1 B 3.4.13-2 Revision 81

Attachment IV to ET 22-0015 Page 3 of 6 RCS Operational LEAKAGE B 3.4.13 BASES LCO b. Unidentified LEAKAGE (continued)

One gallon per minute (gpm) of unidentified LEAKAGE is allowed Separating the sources of leakage (i.e., as a reasonable minimum detectable amount that the containment leakage from an identified source versus air monitoring and containment sump level monitoring equipment leakage from an unidentified source) is necessary for prompt identification of can detect within a reasonable time period. Violation of this LCO potentially adverse conditions, assessment could result in continued degradation of the RCPB, if the LEAKAGE of the safety significance, and corrective is from the pressure boundary.

action.

c. Identified LEAKAGE Up to 10 gpm of identified LEAKAGE is considered allowable because LEAKAGE is from known sources that do not interfere with detection of unidentified LEAKAGE and is well within the capability of the RCS Makeup System. Identified LEAKAGE includes LEAKAGE to the containment from specifically known and located sources, but does not include pressure boundary LEAKAGE or controlled reactor coolant pump (RCP) seal leakoff (a normal function not considered LEAKAGE). Violation of this LCO could result in continued degradation of a component or system.

d. Primary to Secondary LEAKAGE Through Any One SG The limit of 150 gallons per day per SG is based on the operational LEAKAGE performance criterion in NEI 97-06, Steam Generator Program Guidelines, (Ref. 6). The Steam Generator Program operational LEAKAGE performance criterion in NEI 97-06 states, The RCS operational primary to secondary leakage through any one SG shall be limited to 150 gallons per day. The limit is based on operating experience with SG tube degradation mechanisms that result in tube leakage. The operational LEAKAGE rate criterion in conjunction with the implementation of the Steam Generator Program is an effective measure for minimizing the frequency of steam generator tube ruptures.

APPLICABILITY In MODES 1, 2, 3, and 4, the potential for RCS operational LEAKAGE is greatest when the RCS is pressurized.

Wolf Creek - Unit 1 B 3.4.13-3 Revision 29

Attachment IV to ET 22-0015 Page 4 of 6 RCS Operational LEAKAGE B 3.4.13 BASES APPLICABILITY In MODES 5 and 6, RCS operational LEAKAGE limits are not required (continued) because the reactor coolant pressure is far lower, resulting in lower stresses and reduced potentials for LEAKAGE.

LCO 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage," measures leakage through each individual PIV and can impact this LCO. Of the two PIVs in series in each isolated line, leakage measured through one PIV does not result in RCS LEAKAGE when the other is leak tight. If both valves leak and result in a loss of mass from the RCS, the loss must be included in the allowable identified LEAKAGE.

B.1 ACTIONS A.1 INSERT B 3.4.13-4 Unidentified LEAKAGE or identified LEAKAGE in excess of the LCO limits must be reduced to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This Completion Time allows time to verify leakage rates and either identify unidentified LEAKAGE or reduce LEAKAGE to within limits before the reactor must be shut down. This action is necessary to prevent further deterioration of the C.1 and C.2 RCPB.

any of the Required Actions and associated Completion Times cannot be met, B.1 and B.2 If any pressure boundary LEAKAGE exists or primary to secondary LEAKAGE is not within limit, or if unidentified or identified LEAKAGE cannot be reduced to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the reactor must be brought to lower pressure conditions to reduce the severity of the LEAKAGE and its potential consequences. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

The reactor must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This action reduces the LEAKAGE and also reduces the factors that tend to degrade the pressure boundary.

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. In MODE 5, the pressure stresses acting on the RCPB are much lower, and further deterioration is much less likely.

SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS operational LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. It should be noted that LEAKAGE past seals and Wolf Creek - Unit 1 B 3.4.13-4 Revision 35

Attachment IV to ET 22-0015 Page 5 of 6 INSERT B 3.4.13-4 A.1 If pressure boundary LEAKAGE exists, the affected component, pipe, or vessel must be isolated from the RCS by a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. While in this condition, structural integrity of the system should be considered because the structural integrity of the part of the system within the isolation boundary must be maintained under all licensing basis conditions, including consideration of the potential for further degradation of the isolated location. Normal LEAKAGE past the isolation device is acceptable as it will limit RCS LEAKAGE and is included in identified or unidentified LEAKAGE. This action is necessary to prevent further deterioration of the RCPB.

Attachment IV to ET 22-0015 Page 6 of 6 RCS Operational LEAKAGE B 3.4.13 BASES SURVEILLANCE SR 3.4.13.1 (continued)

REQUIREMENTS gaskets is not pressure boundary LEAKAGE. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance.

The RCS water inventory balance must be met with the reactor at steady state operating conditions (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The Surveillance is modified by two Notes. Note 1 states that this SR 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. 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.

Steady state operation is preferred when performing a proper inventory balance since calculations during non-steady state conditions must account for the changing parameters. For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows. An early warning of pressure boundary LEAKAGE or unidentified LEAKAGE is provided by the automatic systems that monitor the containment atmosphere radioactivity and the containment sump level. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. These leakage detection systems are specified in LCO 3.4.15, "RCS Leakage Detection Instrumentation."

Note 2 states that this SR is not applicable to primary to secondary LEAKAGE because LEAKAGE of 150 gallons per day cannot be measured accurately by an RCS water inventory balance. Primary to secondary LEAKAGE is determined by SR 3.4.13.2 and is not determined by an RCS water inventory balance. For determining identified LEAKAGE, identified LEAKAGE includes primary to secondary LEAKAGE as defined in Section 1.1, Definitions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.13.2 This SR verifies that primary to secondary LEAKAGE is less or equal to 150 gallons per day through any one SG. Satisfying the primary to Wolf Creek - Unit 1 B 3.4.13-5 Revision 89