ML23320A277

License Amendment Request to Revise Ventilation Filter Testing Program Criteria in Technical Specification 5.5.11.b and Administrative Correction of Absorber in Technical Specification 5.5.11

ML23320A277
Person / Time
Site:	Wolf Creek
Issue date:	11/16/2023
From:	Boyce M Wolf Creek
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
000208
Download: ML23320A277 (1)

Text

Michael T. Boyce Vice President Engineering November 16, 2023 000208 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket No. 50-482: License Amendment Request to Revise Ventilation Filter Testing Program Criteria in Technical Specification 5.5.11.b and Administrative Correction of Absorber in Technical Specification 5.5.11 Commissioners and Staff:

Pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to Renewed Facility Operating License No. NPF-42 to revise the Technical Specifications (TS) for the Wolf Creek Generating Station (WCGS). The license amendment request (LAR), if approved by the Nuclear Regulatory Commission (NRC), would revise TS 5.5.11.b for the Ventilation Filter Testing Program by changing the testing requirements for the in-place test of the charcoal adsorber penetration and system bypass from less than 0.05% to less than 1% as informed by Generic Letter (GL) 83-13 and Regulatory Guide 1.52, Revision 2. The requested change is based on the charcoal adsorber efficiency assumed in WCGSs safety analysis, as approved by the NRC, and does not impact the frequency by which testing occurs.

Additionally, the LAR would correct an administrative error in TS 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f by changing the word absorber to adsorber.

To support the requested change, Attachment I provides the evaluation and justification for the proposed LAR. Attachment II provides the proposed TS changes (markup) relevant to the requested change. Attachment III provides a markup of the Updated Safety Analysis Report (USAR) for information use only.

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

WCNOC requests approval of this proposed amendment a year following acceptance. Once approved, the amendment will be implemented within 60 days of receipt.

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

000208 Page 2 of 3 This letter contains no 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/nwl Attachment I: Evaluation of Proposed Change Attachment II: Proposed Technical Specification Changes (Markup)

Attachment Ill: Markup of Updated Safety Analysis Report (for information use only) cc: S. S. Lee (NRC), w/a J. Meinholdt (KDHE), w/a J. D. Monninger (NRC), w/a G. E. Werner (NRC), w/a Senior Resident Inspector (NRC), w/a WC Licensing Correspondence, we/a - ET 23-000208

000208 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~

Michael T. Boyce Vice President Engineering SUBSCRIBED and sworn to before me this \ ~ day of NotarPublic Expiration Date _ ____. ) .....-_fldl

\ "_ \...,_ __7_

NA MICHELLE STUCKER JE . S t of Kansas Notary Pubhc - ta ~es ~ - \ \ ~

MY Appo;ntment E)(p;

Attachment I to 000208 Page 1 of 9 EVALUATION OF PROPOSED CHANGE

Subject:

License Amendment Request to Revise Ventilation Filter Testing Program Criteria in Technical Specification 5.5.11.b and Administrative Correction of Absorber in Technical Specification 5.5.11

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES

Attachment I to 000208 Page 2 of 9

1.

SUMMARY

DESCRIPTION The proposed license amendment would revise Technical Specification (TS) 5.5.11.b associated with the Ventilation Filter Testing Program (VFTP). The TS and associated VFTP change would revise the charcoal adsorber in-place test requirement for allowed penetration and system bypass from less than 0.05% to less than 1% based on an iodine filter efficiency of 95% or less contained in Wolf Creek Generating Stations (WCGS) safety analysis, as approved by the Nuclear Regulatory Commission (NRC). The proposed change of revising the allowed penetration and system bypass for the in-place testing of the charcoal adsorbers is aligned with NRC Regulatory Guide 1.52, Revision 2, Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Absorption Units of Light-Water-Cooled Nuclear Power Plants, (Reference 6.1) as informed by Generic Letter (GL) 83-13, Clarification of Surveillance Requirements for HEPA Filters and Charcoal Absorber Units in Standard Technical Specifications on ESF Cleanup Systems, (Reference 6.2). The proposed change also corrects an administrative error by changing the word absorber to adsorber in TS 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f.

2. DETAILED DESCRIPTION 2.1 System Design and Operation The safety-related filtration units containing charcoal adsorbers are located in the fuel building and control building. For the control building, the Control Room Emergency Ventilation System (CREVS) provides a protected, controlled temperature environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

CREVS consists of two independent, redundant trains that recirculate, cool, pressurize, and filter the air in the control room envelope (CRE) and control building envelope (CBE) that limits the in-leakage of unfiltered air. Each CREVS train consists of a recirculation system train and a pressurization train. The filtration portion of each system consists of a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA follows the adsorber section to collect carbon fines.

Each pressurization system train consists of ductwork to bring air from outside the building, a moisture separator, an electric heater, a HEPA, an activated charcoal adsorber, and a second HEPA. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system.

The CREVS is an emergency system which may also operate during normal unit operations. Upon receipt of the actuating signal, normal air supply and exhaust to the CRE is isolated, and a portion of the ventilation air is recirculated through the filtration system train(s), and the pressurization system is started. The filtration system prefilters remove any large particles in the air, and the pressurization system moisture separator removes any entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers. Actuation of the CREVS by a Control Room Ventilation Isolation Signal (CRVIS), places the system in the emergency mode of operation. Actuation of the system in emergency mode of operation closes the unfiltered outside air intake and unfiltered exhaust dampers and aligns the system for recirculation. A portion of the recirculation of the air within the CRE flows through the redundant filtration systems trains of HEPA and the charcoal adsorbers. The CRVIS also initiates pressurization and filtered ventilation of the air supply to the CRE.

Attachment I to 000208 Page 3 of 9 The Emergency Exhaust System serves both the auxiliary building and fuel building. Following a loss of coolant accident (LOCA), safety related dampers isolate the auxiliary building, and the Emergency Exhaust System exhausts potentially contaminated air from the Emergency Core Cooling System areas and from the Hydrogen Purge System. The Emergency Exhaust System filters airborne radioactive particulates from the area of the fuel pool following a fuel handling accident. Following a LOCA, the system is aligned to the auxiliary building; however, a limited amount of air from the fuel building is processed through the Emergency Exhaust System to prevent excessive negative pressure in the auxiliary building.

The Emergency Exhaust System consists of two independent and redundant trains. Each train consists of a heater, a prefilter, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, dampers, and instrumentation also form part of the system, as well as heaters, functioning to reduce the relative humidity of the airstream. The system initiates filtered ventilation of the fuel building following receipt of a fuel building isolation signal. The Emergency Exhaust System is on standby for an automatic start following receipt of a fuel building ventilation isolation signal (FBVIS) or a safety injection signal (SIS). Initiation of the LOCA (SIS) mode of operation takes precedence over any other mode of operation. In the LOCA mode the system is aligned to exhaust the auxiliary building. Upon receipt of a fuel building ventilation isolation signal generated by gaseous radioactivity monitors in the fuel building exhaust line, normal air discharges from the building are terminated, the fuel building is isolated, and the stream of ventilation air discharges through the system filter trains.

The charcoal adsorbers are qualified in accordance with Regulatory Guide 1.52, Revision 2, and are factory tested in accordance with RDT M-16-IT to exhibit a decontamination efficiency of no less than 99.9% for elemental iodine and 98% for methyl iodide. Sample charcoal canisters are tested for impregnant efficiency in an independent laboratory, using radiomethyl iodide tracers.

In-place testing is performed with a suitable refrigerant, in accordance with procedures set forth in ANSI N510, to check for bed bypass leakages.

2.2 Current Technical Specification Requirements Currently, TS 5.5.11.b specifies that WCGS must demonstrate for each of the ESF systems that an inplace test of the charcoal absorber shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2 at the system flowrate specified below +/- 10%.

ESF Ventilation System Flowrate Control Room Emergency Ventilation System 2000 cfm

- Filtration Control Room Emergency Ventilation System 750 cfm

- Pressurization Auxiliary/Fuel Building Emergency Exhaust 6500 cfm TS 5.5.11.b, 5.5.11.c, 5.5.11.d, and TS 5.5.11.f currently utilize the word absorber when referring to the charcoal beds in the respective VFTP testing criteria.

Attachment I to 000208 Page 4 of 9 2.3 Reason for the Proposed Change With the clarifications provided for the relationship between Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 in GL 83-13, the associated surveillance requirements (SR) for testing the charcoal adsorber units are the primary reason for the proposed change. Currently, WCGS TS 5.5.11.b require the in-place halogenated hydrocarbon tests on charcoal adsorber banks to show a 99.95% halogenated hydrocarbon removal. The VFTP stated requirements for an in-place test of the charcoal adsorber to show a penetration and system bypass of less than 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2, does not align with the clarifications provided in GL 83-13. Additionally, the 0.05% value for penetration and system bypass is not the appropriate criteria when iodine filter efficiency in the WCGS approved safety analysis is assumed to be 95% or less, when compared to the clarifications contained in GL 83-13. The conservative testing criteria places an undue burden on the station which could lead to unnecessary system inoperability and unnecessary maintenance. The administrative change proposed for TS 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f revises the term absorber to adsorber as it is the more appropriate term to describe the function of the charcoal beds.

2.4 Description of the Proposed Change The proposed change would revise TS 5.5.11.b associated with the VFTP. The TS and associated VFTP change would revise the charcoal adsorber in-place test requirement for allowed penetration and system bypass from less than 0.05% to less than 1% based on an Iodine filter efficiency of 95% or less contained in the WCGS safety analysis, as approved by the Nuclear Regulatory Commission (NRC). Additionally, the administrative change for changing the word absorber to adsorber is provided to ensure the appropriate technical accuracy of the facility. The mark-up of the changes to TS 5.5.11.b and the associated corrections for the use of absorber for TS 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f are contained in Attachment II.

The proposed changes would also result in a revision of the Updated Safety Analysis Report (USAR) Section 9.4, Table 9.4-2 (Sheet 15). The specific changes to the USAR are detailed in Attachment III and are provided for information use only. Section 9.4 of the USAR describes the design bases, descriptions, tests and inspections, instrument applications, and evaluations for the air conditioning, heating, cooling, and ventilation at WCGS. Table 9.4-2 provides a design comparison to the regulatory position present in Regulatory Guide 1.52, Revision 2. The associated changes for Sheet 15 of Table 9.4-2 would update the comparison response to account for the proposed change from less than 0.05% to less than 1% for charcoal adsorber penetration and system bypass. The associated changes to the USAR will be made following approval of the proposed TS change via the WCGS 10 CFR 50.59 process.

3. TECHNICAL EVALUATION Regulatory Guide 1.52, Revision 2, presents methods acceptable to the NRC staff for implementing the Commissions regulations in Appendix A to 10 CFR Part 50 with regard to the design, testing, and maintenance criteria for air filtration and absorption units of engineered-safety-feature (ESF) atmosphere cleanup systems in light-water-cooled nuclear power plants.

The methods presented only apply to post-accident ESF atmosphere cleanup systems designed to mitigate the consequences of postulated accidents. The proposed change for TS 5.5.11.b involves the ESF systems employed at WCGS and the methods presented in Regulatory Guide 1.52, Revision 2, are applicable. Furthermore, Section 5.d of Regulatory Guide 1.52, Revision 2, states that, the activated carbon adsorber section should be leak tested with a gaseous halogenated hydrocarbon refrigerant in accordance with Section 12 of ANSI N510-1975 to ensure

Attachment I to 000208 Page 5 of 9 that bypass leakage through the adsorber section is less than 0.05%. Currently, TS 5.5.11.b requires the charcoal adsorber shows a penetration and system bypass of less than 0.05%, which is aligned with the guidance presented and is tested accordingly. However, additional clarification was needed to account for the assumed charcoal adsorber efficiency.

On March 2, 1983, GL 83-13 was issued to applicants for operating licenses and holders of construction permits for power reactors and provided additional clarification to clearly reflect the required relationship between the guidance in Regulatory Guide 1.52, Revision 2, and ANSI N510-1975. As a result, the SR associated with testing charcoal adsorber units was modified. The modification accounted for the assumed charcoal adsorber efficiency and states, 0.05% [in reference to penetration and system bypass] value applicable when a HEPA filter or charcoal adsorber efficiency of 99% is assumed, or 1% when a HEPA filter or charcoal adsorber efficiency of 95% or less is assumed in the NRC staffs safety evaluation. The additional clarification presented in GL 83-13 was intended for use in submittal of proposed TS, or in support of necessary changes to TS.

On May 31, 2019, the NRC issued license amendment number 221 to WCGS, Unit 1 (Reference 6.3). The associated safety evaluation (SE) approved the adoption of the alternative source term (AST) radiological analysis methodology described in 10 CFR 50.67, Accident source term. The associated change was a full-scope implementation of the AST as described in Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, dated July 2000. The analysis, as approved by the NRC, contained the following changes to the assumed charcoal adsorber efficiencies:

• Table 4.3-5, Control Room and Control Building Parameters, illustrates that the filter efficiencies assumed for elemental iodine, organic iodine, and particulates are 95%.

• Table 4.3-12, Assumptions Used for LOCA Analysis, illustrates that the auxiliary building exhaust filter efficiency (for all forms of iodine) is 90%.

• Section 4.3.12.2.2 indicates that no credit is taken for filtration in the fuel building or containment for a fuel handling accident.

Therefore, the current licensing basis and assumed charcoal adsorber efficiencies present in the NRC staffs SE align with the clarified criteria contained in GL 83-13. Based on the recommendations presented in GL 83-13, the acceptance criteria for penetration and bypass leakage meets the criteria for less than 1%.

Lastly, when WCGS transitioned to Improved Technical Specifications (ITS) the term adsorber was inadvertently changed to absorber. The use of the word absorber is incorrect for the technical application of the charcoal beds. Adsorber refers to a substance that collects or adsorbs molecules or particles on its surface. On the other hand, absorber refers to a substance that takes in or absorbs another substance. Therefore, to be consistent with the charcoal beds technical application in the facility, the administrative change from absorber to adsorber for TS 5.5.11.b, 5.5.11.c, 5.5.11.d, and 5.5.11.f is acceptable.

Attachment I to 000208 Page 6 of 9

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36(c)(1)(5) - Administrative Controls. Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

10 CFR 50, Appendix A, Criterion 19 - Control room. A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.

Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent, for the duration of the accident. Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.

10 CFR 50, Appendix A, Criterion 41 - Containment atmosphere cleanup. Systems to control fission products, hydrogen, oxygen, and other substances which may be released into the reactor containment shall be provided as necessary to reduce, consistent with the functioning of other associated systems, the concentration and quality of fission products released to the environment following postulated accidents, and to control the concentration of hydrogen or oxygen and other substances in the containment atmosphere following postulated accidents to assure that containment integrity is maintained.

Each system shall have suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) its safety function can be accomplished, assuming a single failure 10 CFR 50, Appendix A, Criterion 43 - Testing of containment atmosphere cleanup systems. The containment atmosphere cleanup systems shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the systems such as fans, filters, dampers, pumps, and valves and (3) the operability of the systems as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the systems into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of associated systems.

10 CFR 50, Appendix A, Criterion 61 - Fuel Storage and handling and radioactivity control. The fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions.

These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection,

Attachment I to 000208 Page 7 of 9 (3) with appropriate containment, confinement, and filtering systems, (4) with a residual heat removal capability having reliability and testability that reflects the importance to safety of decay heat and other residual heat removal, and (5) to prevent significant reduction in fuel storage coolant inventory under accident conditions.

4.2 No Significant Hazards Consideration Wolf Creek Nuclear Operating Corporation (WCNOC) is requesting Nuclear Regulatory Commission (NRC) approval to revise the Technical Specifications (TS) at the Wolf Creek Generating Station (WCGS), Unit 1. The proposed license amendment would revise TS 5.5.11.b associated with the Ventilation Filter Testing Program (VFTP) to allow inplace testing of the charcoal adsorber to show a penetration and system bypass of less than 1% as opposed to the current penetration and system bypass of less than 0.05%, in accordance with Regulatory Guide 1.52, Revision 2, as clarified by Generic Letter (GL) 83-13, Clarification of Surveillance Requirements for HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications on ESF Cleanup Systems. The proposed administrative change for absorber to adsorber is also considered in this request.

WCNOC has evaluated whether or not 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 change associated with TS 5.5.11.b does not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change only impacts the charcoal adsorber testing criteria and do not involve any physical changes to plant systems, structures, or components. The proposed change does not impact initiators of analyzed events and will not increase the probability of occurrence of an accident previously evaluated as the current safety analysis already bounds the proposed changes. The proposed change does not impact the assumed mitigation of accidents or transient events. The proposed change of absorber to adsorber also meets this criteria and is administrative in nature.

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 change associated with TS 5.5.11.b does not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed change does not involve a physical alteration of the plant such as new or different type of equipment being installed, nor does the proposed change modify any methods governing normal plant operation. The proposed change does not allow plant operation in any mode

Attachment I to 000208 Page 8 of 9 that is not already evaluated in the safety analysis. The proposed change of absorber to adsorber also meets this criteria and is administrative in nature.

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 change associated with TS 5.5.11.b does not involve a significant reduction in a margin of safety. GL 83-13 was reviewed for guidance for the proposed change. GL 83-13 based in-place penetration and bypass system leakage testing acceptance criteria in part on the NRC staff assumptions used in its safety evaluations for the ESF atmospheric cleanup systems. GL 83-13 states, 0.05% value applicable when a HEPA filter or charcoal adsorber efficiency of 99% is assumed, or 1% when a HEPA filter or charcoal adsorber efficiency of 95% or less is assumed in the NRC staffs safety evaluation. In the safety evaluation associated with the issuance of license amendment number 221 for WCGS, the NRC approved the adoption of the alternative source term radiological analysis methodology for use at WCGS. The methodology assumes a 95% or less charcoal adsorber efficiency for all applicable ESF atmospheric cleanup systems.

Therefore, GL 83-13 recommends acceptance of less than 1% for penetration and bypass leakage for charcoal adsorbers. The proposed change of absorber to adsorber also meets this criteria and is administrative in nature.

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

4.3 Conclusions In conclusion, based on the considerations above, (i) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (ii) such activities will be conducted in compliance with the Commissions regulations, and (iii) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENAL CONSIDERATIONS The proposed change would revise a requirement for the allowed penetration and system bypass associated with charcoal adsorbers for WCGS and corrects an administrative error for the use of the word absorber. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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 amendment meets the eligibility criterion for categorical exclusion set forth in paragraph (c)(9) of 10 CFR 51.22, Criterion of categorical exclusion, identification of licensing and regulatory actions eligible for categorical exclusion otherwise not requiring an environmental review. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Attachment I to 000208 Page 9 of 9

6. REFERENCES 6.1 U.S. Nuclear Regulatory Commission Regulatory Guide 1.52, Revision 2, Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Absorption Units of Light-Water-Cooled Nuclear Power Plants, March 1978.

6.2 U.S. Nuclear Regulatory Commission Generic Letter No. 83-13, Clarification of Surveillance Requirements for HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications on ESF Cleanup Systems, March 2, 1983.

6.3 Letter from USNRC, dated May 31, 2019, from B. K. Singal, USNRC, to A. Heflin, WCNOC, Wolf Creek Generating Station, Unit 1 - issuance of Amendment No. 221 Re:

Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term (CAC No. MF9307; EPID L-2017-LLA-0211) (ML19100A122)

Attachment II to 000208 Page 1 of 3 Proposed Technical Specification Changes (Markup)

Attachment II to 000208 Programs and Manuals Page 2 of 3 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program (VFTP) (continued) 1%

b. Demonstrate for each of the ESF systems that an inplace test of the adsorber charcoal absorber shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 2 at the system flowrate specified below 10%.

ESF Ventilation System Flowrate Control Room Emergency Ventilation System - Filtration 2000 cfm Control Room Emergency Ventilation System-Pressurization 750 cfm Auxiliary/Fuel Building Emergency Exhaust 6500 cfm

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal absorber, when obtained as described in adsorber Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30 C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration RH Control Room Emergency Ventilation System (Filtration/Pressurization) 2.5% 70%

Auxiliary/Fuel Building Emergency Exhaust 5% 70%

d. Demonstrate at least once per 18 months for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal absorbers is less than the value specified below when adsorbers tested in accordance with Regulatory Guide 1.52, Revision 2, at the system flowrate specified below 10%.

ESF Ventilation System Delta P Flowrate Control Room Emergency Ventilation System - Filtration 6.6 in. W.G. 2000 cfm Control Room Emergency Ventilation System - Pressurization 3.6 in. W.G. 750 cfm Auxiliary/Fuel Building Emergency Exhaust 4.7 in. W.G. 6500 cfm (continued)

Wolf Creek - Unit 1 5.0-15 Amendment No. 123, 131, 139, 164

Attachment II to 000208 Programs and Manuals Page 3 of 3 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program (VFTP) (continued)

e. Demonstrate at least once per 18 months that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1975.

ESF Ventilation System Wattage Control Room Emergency Ventilation System - Pressurization 5 1 kW Auxiliary/Fuel Building Emergency Exhaust 37 3 kW

f. Demonstrate at least once per 18 months for each of the ESF systems that following the creation of an artificial Delta P across the combined HEPA filters, the prefilters, and the charcoal absorbers of not less than the value specified below (dirty filter conditions), that the flowrate through these flow paths is with +/- 10% of the value specified below when tested in accordance with ANSI N510-1980.

adsorbers ESF Ventilation System Delta P Flowrate Control Room Filtration System 6.6 in. W.G. 2000 cfm Control Room Pressurization System 3.6 in. W.G. 750 cfm Auxiliary/Fuel Building Emergency Exhaust 4.7 in. W.G. 6500 cfm The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, Revision 0, July 1981, "Postulated Radioactive Release due to Waste Gas System Leak or Failure." The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Revision 2, July 1981, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures."

(continued)

Wolf Creek - Unit 1 5.0-16 Amendment No. 123, 131, 164

Attachment III to 000208 Page 1 of 3 Markup of Updated Safety Analysis Report (For Information Use Only)

Attachment III to 000208 WOLF CREEK Page 2 of 3 TABLE 9.4-2 (Sheet 15)

Regulatory Guide 1.52 Position feature air filtration system The in-place DOP testing satisfying this condition is performed in accor can be considered to dance with Section 10 of warrant a 99% removal ANSI N510-1075, but the efficiency for particulates prerequisite testing in in accident dose evaluations. Sections 8 and 9 is per HEPA filters that fail to formed in accordance satisfy this condition with the 1980 version in would be replaced with lieu of the 1975 version filters qualified pursuant except that DOP is not to regulatory position C.3.d injected between the two of this guide. If the HEPA HEPA banks.

filter bank is entirely or only partially replaced, an in-place DOP test should be conducted. If any welding repairs are necessary on, within, or adjacent to the ducts, housing, or mounting frames, the filters and adsorbers should be removed from the housing during such repairs. The repairs should be completed prior to periodic testing, filter See USAR Insert inspection, and in-place testing. The use of silicone sealants or any other temporary patching material on filters, housing, mounting frames, or ducts should not be allowed.

d. The activated carbon d. Complies, except that adsorber section should be the prerequisite testing leak tested with a gaseous in Sections 8 and 9 is halogenated hydrocarbon re performed in accordance frigerant in accordance with with ANSI N510-1980.

Section 12 of ANSI N510-1975 (Ref. 2) to ensure that bypass leakage through the adsorber section is less than 0.05%. After the test is completed, air flow through the unit should be Rev. 0

Attachment III to 000208 Page 3 of 3 USAR Insert Complies, except that the Technical Specification acceptance criteria of less than 1.0 percent in-place penetration and bypass leakage shall be employed. The Technical Specification requirements, although less stringent than the Reg. Guide, still allow a conservative design, as the accident dose evaluation assumes a 95 percent efficiency for all forms of iodine for the control building pressurization and control building filtration filter adsorber units (GK system). An efficiency of 90 percent is assumed for the auxiliary/fuel building emergency exhaust system filter adsorber units (GG System) for all forms of iodine in the ECCS leakage dose pathway. The in-place adsorber testing will be performed in accordance with Section 12 of ANSI N510-1975, but the prerequisite testing in Sections 8 and 9 will be performed in accordance with the 1980 version in lieu of the 1975 version. Air/aerosol mixing is not performed on the downstream banks.