ML24227A556
| ML24227A556 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/14/2024 |
| From: | Boyce M Wolf Creek |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 000496 | |
| Download: ML24227A556 (1) | |
Text
Michael T. Boyce Vice President Engineering
August 14, 2024 000496
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555- 0001
Subject:
Docket No. 50-482: Application to Revise Technical Specifications to Adopt TSTF-569-A, Revision 2, Revision of Response Time Testing Definitions
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) is submitting a request for an amendment to the Technical Specifications (TS) for Wolf Creek Generating Station (WCGS).
WCNOC requests adoption of Technical Specification Task Force (TSTF)-569-A, Revision 2, Revise Response Time Testing Definition, which is an approved change to the Improved Standard Technical Specifications (ISTS) into the WCGS TS. The proposed amendment revises the TS Definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time.
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 the revised (clean) TS pages. Attachment IV provides the existing TS Bases pages marked to show the proposed changes for information only.
WCNOC requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 90 days.
The amendment application was reviewed by the WCGSs Plant Safety Review Committee. I n 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.
This letter contains no regulatory commitments.
P.O. Box 411 l Burlington, KS 66839 l 620- 364-8831 000496 Page 2 of 3
If you should have any questions regarding this submittal, 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 J. D. Monninger (NRC), w/a J. Meinholdt (KDHE), w/a G. E. Werner (NRC), w/a Senior Resident Inspector (NRC), w/a Licensing Correspondence - ET 24-000496, w/a
Attachment I to 000496 Page 1 of 5
EVALUATION OF PROPOSED CHANGE
Subject:
Application to Revise Technical Specifications to Adopt TSTF-569-A, Revision 2, Revision of Response Time Testing Definitions
1.0 DESCRIPTION
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation
2.2 Variations
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination
3.2 Conclusions
4.0 ENVIRONMENTAL EVALUATION Attachment I to 000496 Page 2 of 5
1.0 DESCRIPTION
Wolf Creek Nuclear Operating Corporation (WCNOC) requests adoption of TSTF-569-A, Revision 2, Revise Response Time Testing Definition, which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Wolf Creek Generating Station (WCGS)
Technical Specifications (TS). The proposed amendment revises the TS Definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time.
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation
WCNOC has reviewed the safety evaluation for TSTF-569-A, Revision 2, provided to the Technical Specification Task Force in a letter dated August 14, 2019 (ADAMS Accession No. ML19176A191). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-569-A, Revision 2. As described herein, WCNOC has concluded that the justifications presented in TSTF-569-A, Revision 2, and the safety evaluation prepared by the NRC staff are applicable to WCGS and justify this amendment for the incorporation of the changes to the WCGS TS.
2.2 Variations
WCNOC is proposing the following variation from the TS changes described in the TSTF-569-A, Revision 2.
- The WCGS TS Definition of ESF Response Time contains slightly different wording compared to the ISTS of NUREG 1431, Standard Technical Specifications -
Westinghouse Plants, as described in TSTF-569-A, Revision 2. The WCGS TS states,
The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function. T he ISTS of NUREG 1431 states, The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function. The WCGS TS restates the acronym ESF prior to the term actuation, while the ISTS of NUREG 1431 does not.
The difference between the WCGS TS and the ISTS of NUREG 1431 do not affect the applicability of TSTF-569-A, Revision 2, to the WCGS TS and is considered an administrative variation.
The WCGS TS Bases, which is provided for information use only, also contains additional markups and varies when compared to the TSTF-569-A, Revision 2, model application. When WCGS transitioned to the ISTS, WCAP-13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, was incorporated into the TS Bases and approved the elimination of pressure sensor response time testing for select sensors identified in the WCAP.
WCGS did not incorporate WCAP-14036-P-A, Revision 1, Elimin ation of Periodic Protection Channel response Time Tests, into the TS Bases but made the appropriate changes to the TS as required by the WCAP for implementation when transitioning to the ISTS. The TS Bases markups contain additional information, showing the addition of WCAP-14036-P-A, Revision 1, into the Surveillance Requirement (SR) discussion for SR 3.3.1.16 and SR 3.3.2.10. The WCAP is also added to the list of references for the applicable SRs to align with the model application Attachment I to 000496 Page 3 of 5
as it references both of the technical documents as part of the markups and basis of the proposed change. The additional information added to the TS Bases markups (for information use only) does not affect the applicability of TSTF-569-A, Revision 2, to the WCGS and is considered an administrative variation.
No variations are taken with respect to the NRC staffs safety evaluation for TSTF-569-A, Revision 2.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination
Wolf Creek Nuclear Operating Corporation (WCNOC) requests adoption of TSTF-569-A, Revision 2, Revise Response Time Testing Definition, which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Wolf Creek Generating Station (WCGS)
Technical Specifications (TS). The proposed amendment revises the TS Definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time.
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 change revises the TS Definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The requirement for the instrumentation to actuate within the response time assumed in the accident analysis is unaffected.
The response time associated with the RTS and ESF instrumentation is not an initiator of any accident. Therefore, the proposed change has no significant effect on the probability of any accident previously evaluated.
The affected RTS and ESF instrumentation are assumed to actuate their respective components within the required response time to mitigate accidents previously evaluated.
Revising the TS Definition for RTS and ESF instrumentation response times to allow an NRC-approved methodology for verifying response time for some components does not alter the surveillance requirements that verify the RTS and ESF instrumentation response times are within the required limits. As such, the TS will continue to assure that the RTS and ESF instrumentation actuate their associated components within the specified response time to accomplish the required safety functions assumed in the accident analyses. Therefore, the assumptions used in any accidents previously evaluated are unchanged and there is no significant increase in the consequences.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Attachment I to 000496 Page 4 of 5
Response: No
The proposed change revises the TS Definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The proposed change does not alter any assumptions made in the safety analyses. The proposed change does not alter the limiting conditions for operation for the RTS or ESF instrumentation, nor does it change the Surveillance Requirement to verify the RTS and ESF instrumentation response times are within the required limits. As such, the proposed change does not alter the operability requirements for the RTS and ESF instrumentation, and therefore, does not introduce any new failure modes.
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 revises the TS Definition of RTS and ESF instrumentation response time to permit the licensee to evaluate using an NRC -approved methodology and apply a bounding response time for some components in lieu of measurement. The proposed change has no effect on the required RTS and ESF instrumentation response times or setpoints assumed in the safety analyses and the TS requirements to verify those response times and setpoints. The proposed change does not alter any Safety Limits or analytical limits in the safety analysis. The proposed change does not alter the TS operability requirements for the RTS and ESF instrumentation. The RTS and ESF instrumentation actuation of the required systems and components at the required setpoints and within the specified response times will continue to accomplish the design basis safety functions of the associated systems and components in the same manner as before. As such, the RTS and ESF instrumentation will continue to perform the required safety functions as assumed in the safety analyses for all previously evaluated accidents.
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.
3.2 Conclusions
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.
Attachment I to 000496 Page 5 of 5
4.0 ENVIRONMENTAL EVALUATION
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 000496 Page 1 of 3
Proposed Technical Specification Changes (Mark-up)
Attachment II to 000496 Definitions Page 2 of 3 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
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, 236 Attachment II to 000496 Definitions Page 3 of 3 1.1
1.1 Definitions (continued)
PRESSURE AND The PTLR is the unit specific document that provides the TEMPERATURE LIMITS reactor vessel pressure and temperature limits, including REPORT (PTLR) heatup and cooldown rates and the power operated relief valve lift settings and the Low Temperature Overpressure Protection (LTOP) System arming temperature, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6.
QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore RATIO (QPTR) detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.
RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 3565 MWt.
REACTOR TRIP The RTS RESPONSE TIME shall be that time interval from SYSTEM (RTS) RESPONSE when the monitored parameter exceeds its RTS trip setpoint TIME at the channel sensor until loss of stationary gripper coil voltage. 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.
SHUTDOWN MARGIN (SDM) SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:
- a. All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and
- b. In MODES 1 and 2, the fuel and moderator temperatures are changed to the hot zero power temperatures.
(continued)
Wolf Creek - Unit 1 1.1-5 Amendment No. 123, 170, 180, 221 Attachment III to 000496 Page 1 of 3
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, or the components have been evaluated in accordance with an NRC approved methodology.
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, 236 Definitions 1.1
1.1 Definitions (continued)
PRESSURE AND The PTLR is the unit spec ific document that provides the TEMPERATURE LIMITS reactor vessel pressure and temperature limits, including REPORT (PTLR) heatup and cooldown rates and the power operated relief valve lift settings and the Low Temperature Overpressure Protection (LTOP) System arming temperature, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6.
QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore RATIO (QPTR) detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.
RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 3565 MWt.
REACTOR TRIP The RTS RESPONSE TIME shall be that time interval from SYSTEM (RTS) RESPONSE when the monitored parameter exceeds its RTS trip setpoint TIME at the channel sensor until loss of stationary gripper coil voltage. 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, or the components have been evaluated in accordance with an NRC approved methodology.
SHUTDOWN MARGIN (SDM) SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:
- a. All rod cluster control assemblies (RCCAs) are fu lly inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and
- b. In MODES 1 and 2, the fuel and moderator temperatures are changed to the hot zero power temperatures.
(continued)
Wolf Creek - Unit 1 1.1-5 Amendment No. 123, 170, 180, 221 Attachment IV to 000496 Page 1 of 7
Proposed Technical Specification Bases Changes (Mark-Up) For Information Only
Attachment IV to 000496 RTS Instrumentation Page 2 of 7 B 3.3.1
BASES
SURVEILLANCE SR 3.3.1.16 (continued)
REQUIREMENTS channels with response times listed as N.A. No response time testing requirements apply where N.A. is listed in Table B 3.3.1-2. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor until loss of stationary gripper coil voltage.
For channels that include dynamic transfer Functions (e.g., lag, lead/lag, rate/lag, etc.), the response time verification is performed with the time constants set at their nominal values. The response time may be measured by a series of overlapping tests, or other verification (e.g.,
Ref. 7), such that the entire response time is measured.
Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated response times with actual response time tests on the remainder of the channel. Allocations for response times may be obtained from: (1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) inplace, onsite, or offsite (e.g. vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A Revision 2,
(Ref. 7), provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.
The allocations for sensor response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. One example where response time could be affected is replacing the sensing assembly of a transmitter.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.3.1.16 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal.
Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response. Response time of the neutron flux signal portion of the channel shall be measured from detector output or input to the first electronic component in the channel.
Wolf Creek - Unit 1 B 3.3.1-56 Revision 89 Attachment IV to 000496 Page. of 7
Insert 1 :
WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, (Ref. 14) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re -verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.
The response time may be verified for components that replace the components that were previously evaluated in Ref. 6 and Ref. 14, provid ed that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF -569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 15).
Attachment IV to 000496 RTS Instrumentation Page 4 of 7 B 3.3.1
BASES
REFERENCES 1. USAR, Chapter 7.
- 2. USAR, Chapter 15.
- 3. IEEE-279-1971.
- 4. 10 CFR 50.49.
- 5. WCNOC Nuclear Safety Analysis Setpoint Methodology for the Reactor Protection System, (TR-89-0001).
September 14, 1979.
August 29, 1984.
- 10. USAR, Table 15.0-4.
1998.
RTS and ESFAS Surveillance Test Intervals and Reactor Trip
Time and Completion Time Technical Specification Changes for
20, 2006.
Wolf Creek - Unit 1 B 3.3.1-57 Revision 89 Attachment IV to 000496 ESFAS Instrumentation Page 5 of 7 B 3.3.2
BASES
SURVEILLANCE SR 3.3.2.10 (continued)
REQUIREMENTS response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.
The allocations for sensor response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. One example where response time could be affected is replacing the sensing assembly of a transmitter.
Rules for Preservice and Inservice Testing of Certain Electric Motor-
alternative to stroke time testing for motor-operated valves (Ref. 14). The parameters that must be present to achieve the analyzed response time under design basis conditions are measured to ensure the valve is capable of performing its safety function. This process verifies design basis capability, including response time, and is a significant improvement over simple stroke time measurement. This process allows the establishment of periodic valve test intervals if there is assurance that the valve will remain capable of performing its safety function throughout the interval.
ESF response times specified in Table B 3.3.2-2 which include sequential operation of RWST and VCT valves (Notes 3 and 4) are based on values assumed in the non-LOCA safety analyses. These analyses take credit for injection of borated water from the RWST. Injection of borated water is assumed not to occur until the VCT charging pump suction valves are closed following opening of the RWST charging pump suction valves.
When the sequential operation of the RWST and VCT valves is not included in the response times (Note 7), the values specified are based on the LOCA analyses. The LOCA analyses take credit for injection flow regardless of the source. Verification of the response times specified in Table B 3.3.2-2 will assure that the assumptions used for the LOCA and non-LOCA analyses with respect to the operation of the VCT and RWST valves are valid.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 900 psig in the SGs.
Wolf Creek - Unit 1 B 3.3.2-50 Revision 89 Attachment IV to 000496 Page of 7
Insert 2:
WCAP-1 4036-P-A, Revision 1, E limination o f Periodic P rotection C hannel Response Time Tests, (Ref. 1 5) provides t he b asis an d methodology f or u sing allocated s ignal processing and actuation logic response times i n the overall verification of the pr otection system c hannel response t ime. T he allocations f or sensor, signal conditioning, and actuation logic response times must be v erified prior to placing the c omponent in operational s ervice and r e-verified following main tenance that may a dversely a ffect response time. I n general, e lectrical re pair work does not impact response ti me provided the parts used for re pair are of the s ame type and value. S pecific components identified in the WCAP may be replaced without verification testing. O ne e xample where response time could be a ffected i s replacing the s ensing assembly of a transmitter.
The response time may be v erified for components that replace the components t hat were previously evaluated in R ef. 8 and Ref. 15, provided that t he c omponents have been evaluated in accordance with the N RC approved methodology a s discussed in Attachment 1 to T STF-569, Methodology to Eliminate P ressure Sensor and Protection Channel ( for Westinghouse P lants only) Response Time Testing, (Ref. 1 6).
Attachment IV to 000496 ESFAS Instrumentation Page 7 of 7 B 3.3.2
BASES
REFERENCES 1. USAR, Chapter 6.
- 2. USAR, Chapter 7.
- 3. USAR, Chapter 15.
- 4. IEEE-279-1971.
- 5. 10 CFR 50.49.
- 6. WCNOC Nuclear Safety Analysis Setpoint Methodology for the Reactor Protection System, TR-89-0001.
- 7. WCAP-10271-P-A Supplement 2, Revision 1, "Evaluation of Surveillance Frequencies and Out of Service Times for the Engineered Safety Features Actuation System," June 1990.
29, 1984.
- 10. Amendment No. 43 to Facility Operating License No. NPF-42, March 29, 1991.
1998.
- 12. 10 CFR 50.55a(b)(3)(iii), Code Case OMN-1.
- 13. Performance Improvement Request (PIR) 2005-2067.
- 14. Amendment No. 231 to Renewed Facility Operating License No.
NPF-42, February 23, 2022.
Wolf Creek - Unit 1 B 3.3.2-52 Revision 91