Text

Operating Corporation, Request for Correction in Response to Issuance of Amendment No. 237 and Corresponding Safety Evaluation
	ML23292A357
Person / Time
Site:	Wolf Creek
Issue date:	10/19/2023
From:	Boyce M; Wolf Creek
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	000163
	Download: ML23292A357 (45)
	v • d • e

Michael T. Boyce Vice President Engineering

October 19, 2023 000163

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Reference:

1) Letter ET 22-0010, dated August 2, 2022, from M. T. Boyce, WCNOC, to USNRC, License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements (ML22215A000)

2) Letter ET 23-0004, dated January 26, 2023, from M. T. Boyce, WCNOC, to USNRC, Response to Requests for Additional Information (RAI) Regarding License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements (ML23026A359)

3) Letter 000048 / ET 23-000048, dated August 8, 2023, from M. T. Boyce, WCNOC, to USNRC, Supplement to License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements (ML23220A422)

4) Letter from USNRC, dated August 31, 2023, from S. S. Lee, USNRC, to C. Reasoner, WCNOC, Wolf Creek Generating Station, Unit 1 -

Issuance of Amendment No. 237 Re: Request for Deviation from Fire Protection Program Requirements (EPID: L-2022-LLA-0107)

(ML23165A250)

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporation Request for Correction in Response to Issuance of Amendment No. 237 and Corresponding Safety Evaluation

Commissioners and Staff:

On August 31, 2023, Wolf Creek Nuclear Operating Corporation (WCNOC) obtained approval from the Nuclear Regulatory Commission (NRC) for Amendment No. 237 (Reference 4) addressing the use of portable lighting as the primary emergency lighting means for illuminating safe shutdown equipment and access egress routes to the equipment. Following issuance of NRC Amendment No. 237, WCNOC performed a technical review of the issued amendment. During that review, it was discovered that although License Condition 2.C(5) and the approved Updated Safety Analysis Report (USAR) change pages agree with what WCNOC requested, the

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

ET 23-000163 Page 2 of 4

supporting information in the NRCs Safety Evaluation (SE) significantly deviates from what WCNOC provided in its license amendment request (LAR) sent to the NRC on August 2, 2022 (Reference 1), as supplemented (see References 3 and 4).

For example, the issued SE did not discuss the use of portable lighting as a primary emergency lighting means, which is the core of the LAR. Instead, it discussed the use of portable lighting in specific fire areas affected by a fire event. Also, because the SE discussion is much more limiting than what was requested by WCNOC, the SE also appears to be inconsistent with WCNOCs No Significant Hazards Consideration (NSHC) that was published in the Federal Register pursuant to 10 CFR 50.90 [87 FR 60217]. In addition, the NSHC appears to be inconsistent with the SE as currently written because the SE includes additional information that was not a part of the proposed changes and therefore, also was not part of WCNOCs NSHC review.

WCNOC requests that the NRC correct the SE by letter which is consistent with NRR Office Instruction LIC-101, Licensing Amendment Review Process, Revision 6, Appendix B, Section 6.4, which states that An amendment package consists of other documents, such as the SE and the transmittal letter. These other documents, since they are not legally binding and not specifically addressed by SECY-96-238 [which refers to legally binding documents], may be corrected by letter. Note, changes to the SE must be consistent with docketed information provided in the licensees application and associated supplements. In this instance, the SE issued by the NRC is not consistent with the docketed information provided in the WCNOC LAR or its supplements.

Although the SE is not part of the licensing basis, it is relied upon by the NRC when confirming compliance with the associated changes. Therefore, having a correctly worded SE is important.

The effect of an SE that is not consistent with an LAR is that it can establish new interpretations of the facility licensing basis. LIC-101, which references NRR Office Instruction LIC-100, Control of Licensing Bases for Operating Reactors, Revision 1, dated January 7, 2004, states that, the NRC staff should not attempt to establish licensing bases information in SEs. It is important that licensees provide the licensing bases information so that there is no confusion following the licensing action and to avoid a perception of staff-imposed backfits (see 10 CFR 50.109). See LIC-101, Revision 6, Appendix B, Section 4.0. The NRC-issued SE does introduce staff conclusions that arguably supports an unrequested change to the facility licensing basis. As such, the NRC should modify the WCNOC SE to prevent these regulatory interpretation inconsistencies.

To resolve the above concerns, WCNOC is providing a discussion on the deviations in Attachment I that illustrates the original request as provided by WCNOC, what was provided by the NRC in the SE, and why the information needs correction. Attachment I also provides a cross-reference of the deviations to the markups provided in Attachment II. Additionally, WCNOC is providing a markup version of the NRC-issued SE to correct erroneous information and to eliminate the discussion of issues that WCNOC did not request be included in the subject LAR. The redlined version in Attachment II is consistent with the requested scope of the original LAR. Attachment III provides a clean version of the SE with the corrections incorporated. Names, signatures, and headers were removed from the clean pages. The SE markups make the SE consistent with what was noticed in the Federal Register under 10 CFR 50.90, and the NSHC consistent with 10 CFR 50.92(c) and 10 CFR 50.91, Notice for Public Comment.

ET 23-000163 Page 3 of 4

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

Attachments: I Comments on Information Provided in Safety Evaluation in Reference 4 II Markup of Safety Evaluation Provided in Reference 4 111 Safety Evaluation with Markups Incorporated (Clean Pages)

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 Licensing Correspondence - ET 23-000163 ET 23-000163 Page 4 of 4

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 l q day of ~1/4, 2023.

Expiration Date \\ - l l - fl D 21 Attachment I to ET 23-000163 Page 1 of 11

Comments on Information Provided in Safety Evaluation in Reference 4

Attachment I to ET 23-000163 Page 2 of 11

1.0 Original Wolf Creek Request from LAR (Comment 1)

The license amendment request (LAR) submitted to the NRC on 8/2/2022 Attachment I, Section 2, Detailed Description, states the following:

With limited exception, portable lighting will be the primary illumination means for implementing procedures, safe shutdown equipment, and the respective access egress routes to the equipment in support of post-fire shutdown or a non-fire event resulting in the loss of all AC power. This encompasses the following WCGS procedure scope:

OFN RP-017, "Control Room Evacuation" OFN KC-016, "Fire Response" EMG C-0, "Loss of All AC Power" OFN NB-034, "Loss of All AC Power - Shutdown Conditions"

This procedure scope is also included in Section 2.5 and E.2 of WIP-E-1F9900-010-A-1; which is Enclosure 1 to Reference 1, as supplemented. The acceptability of utilizing portable lighting in the implementation of these procedures is analyzed for feasibility and reliability in Section E.10 of WIP-E-1F9900-010-A-1.

Additionally, the No Significant Hazards Consideration (NSHC) in Section 4.2 of Reference 1 states, The proposed amendment credits the use of portable lighting in certain applications as the primary emergency lighting means for illuminating implementing procedures, safe shutdown equipment, and the respective access and egress routes to the equipment in support of post-fire safe shutdown or a non-fire event resulting in the loss of all AC power.

1.1 NRC Safety Evaluation Discussion

Safety Evaluation (SE), Section 3.0, Technical Evaluation, Table 1.

1.2 Why NRC Safety Evaluation Needs Correction

The SE only addresses the acceptability for portable lighting for fires outside the control room (OFN KC-016, though not specifically called out in the SE) and does not directly address the use of portable lighting for implementation of operator actions for OFN RP-017, EMG C-0, OFN NB-034, and OFN KC-016. However, the proposed revision to Wolf Creek Updated Safety Analysis Report (USAR) section 9.5.3.2.3 was approved in Reference 4 and describes the operator manual actions (OMAs) strategy for post-fire safe shutdown and non-fire events resulting in loss of all AC power. Therefore, the SE is not consistent with nor does it adequately disposition the docketed information provided in the Wolf Creek LAR. Specific OMAs and fire areas were not called out for approval in the LAR for two primary reasons:

The fundamental evaluation for portable lighting acceptability throughout the power block is the same, independent of the action being taken.

Attachment I to ET 23-000163 Page 3 of 11

Future revision to OFN RP-017, OFN KC-016, EMG C-0, OFN NB-034 for the addition of an OMA would not be bounded by the LAR and subsequent SE.

Additionally, the absence of these procedures in the SE does not align with the NSHC conclusions reached in the original submittal. To correct this deviation, all procedures must be included and addressed.

2.0 Original Wolf Creek Request from LAR (Comment 2)

As identified in Comment 1, Wolf Creek requested approval for the use of portable lighting as the primary emergency lighting means associated with OMAs for procedures OFN RP-017, EMG C-0, OFN NB-034, and OFN KC-016. Section E.2.5 of WIP-E-1F9900-010-A-1 identified that the Table E.2.5-1 emergency lights would continue to be credited as 8-hour capacity emergency lighting. Section E.9.2 of WIP-E-1F9900-010-A-1 identifies that fixed emergency lighting units, excluding those identified in Table E.2.5-1, will remain installed in the plant but will be treated comparable to life safety emergency lighting from a battery life (1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ) and preventive maintenance perspective. This lighting is considered supplemental to portable lighting.

2.1 NRC Safety Evaluation Discussion

The responsive section in the SE, Section 3.0, Technical Evaluation, states:

The licensee requested to use hard hat mounted portable lights as an alternative for fixed emergency lighting units in the fire areas listed in table 1 of this safety evaluation (SE),

where operator manual actions are performed.

2.2 Why NRC Safety Evaluation Needs Correction

The LAR does not request specific fire areas to be included for portable lighting consideration but requests specific implementing procedures that require OMAs. It does not appear that this specific request is addressed in the SE.

The fire areas identified in Table 1 from the SE Technical Evaluation, Section 3.0, are the locations where, if a fire were to occur, OMAs in other locations may be required. The required actions to achieve and maintain post-fire safe shutdown take place outside of the listed Table 1 fire affected fire areas. For example, a fire in Fire Area C-21 may require an OMA in Fire Area A-25 and C-9 per Attachment A of E-1F9900. This Attachment identifies that Fire Areas A-23, A-25, C-9, and C-10 are the locations where OMAs may be required as a result of a fire outside the control room (OFN KC-016 scope).

As written, the SE cannot be implemented. The Table 1 fire areas identified in the SE do not require OMA response within the fire affected area, and thus portable lighting would not be needed for the SE identified fire areas.

Attachment I to ET 23-000163 Page 4 of 11

Specific OMAs and fire areas were not called out for approval in the LAR for two primary reasons:

The fundamental evaluation for portable lighting acceptability throughout the power block is the same, independent of the action being taken.

Future revision to OFN RP-017, OFN KC-016, EMG C-0, OFN NB-034 for the addition of an OMA would not be bounded by the LAR and subsequent SE.

The SE is not consistent with nor does it adequately disposition the docketed information provided in the Wolf Creek LAR.

3.0 Original Wolf Creek Request from LAR (Comment 3)

As identified in Comment 1 above, Wolf Creek requested approval for the use of portable lighting as the primary emergency lighting means associated with OMAs for procedures OFN RP-017, EMG C-0, OFN NB-034, and OFN KC-016.

3.1 NRC Safety Evaluation Discussion

SE, Section 3.1, Staff Evaluation, states:

In plant areas, where installation of 8-hour battery backup supplied lighting is not achievable, the hard hat mounted portable lights accomplish the purpose of achieving adequate emergency lighting because they will ensure that adequate lighting is available to aid the operator for an extended period of time during plant fire emergencies.

3.2 Why NRC Safety Evaluation Needs Correction

The referenced statement in the SE is incorrect. The LAR submittal did not request approval of limited portable lighting use for only the specific situations listed by the NRC. Furthermore, the LAR did not state that there were areas where installation of 8-hour fixed emergency lighting is not achievable.

4.0 Original Wolf Creek Request from LAR (Comment 4)

Table E.2.5-1 from WIP-E-1F9900-010-A-1 identifies the fixed emergency lighting units that will continue to be credited as 8-hour battery capacity in the emergency lighting illumination response strategy for safe shutdown.

Attachment I to ET 23-000163 Page 5 of 11

4.1 NRC Safety Evaluation Discussion

Consistent with Table E.2.5-1 from WIP-E-1F9900-010-A-1, the SE Section 3.0, Technical Evaluation, Table 2 identifies the fixed emergency lighting units that will continue to be credited as 8-hour battery capacity in the emergency lighting illumination response strategy for safe shutdown.

4.2 Why NRC Safety Evaluation Needs Correction

The evaluation in Section 3.0 of the SE is incomplete, as it does not acknowledge that the remaining 8-hour fixed emergency lighting units at the Station will remain in place, but be downgraded to 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Life Safety lights, as discussed in Section E.9.2 of WIP-E-1F9900-010-A-1. The SE is not consistent with nor does it adequately disposition the docketed information provided in the Wolf Creek LAR.

5.0 Original Wolf Creek Request from LAR (Comment 5)

Section 2.0, Detailed Description from the LAR states the following:

USAR Appendix 9.5E provides a design comparison to 10 CFR 50 Appendix R and how WCGS compares with the specific requirements of 10 CFR 50 Appendix R. Specifically,Section III.J of 10 CFR 50 Appendix R states the following: "Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto." WCGS's response to the requirement was: "The Power block Complies. As stated in Section 9.5.3.2.3, emergency lighting units with eight-hour batteries are located in all plant areas required for operation of safe shutdown equipment and also those areas necessary for access and egress. The ESW pumphouse also complies."

5.1 NRC Safety Evaluation Discussion

The following statement is provided in the SE Section 2.1, Program Description and Regulatory Requirements:

Wolf Creek was licensed to operate on June 4, 1985, and thus, is not subject to Appendix R to 10 CFR Part 50. However, the licensee committed to meet the requirements of Appendix R to 10 CFR Part 50, Section III.J to provide emergency lighting to assure safe shutdown capability is maintained during and after a fire.

Attachment I to ET 23-000163 Page 6 of 11

5.2 Why NRC Safety Evaluation Needs Correction

The statement as written in the SE is incorrect. Wolf Creek has not committed to 10 CFR 50 Appendix R and therefore, the NRC SE statement inappropriately modifies the Wolf Creek licensing basis and commitments. Wolf Creek provided a comparison response to 10 CFR 50 Appendix R, as documented in USAR Appendix 9.5E. This comparison response is part of the Approved Fire Protection Program. This is discussed in Attachment I, Page 3 and 7 of the LAR submittal (Reference 1). Wolf Creek requests that the statement be corrected to prevent inadvertent commitments or future confusion with regards to its Fire Protection Licensing Basis.

6.0 Original Wolf Creek Request from LAR (Comment 6)

Section 9.5.3.2.3 of the USAR markup provided an unchanged paragraph identifying that Class IE power is provided for lighting fixtures above the main control board and operators console.

6.1 NRC Safety Evaluation Discussion

SE, Section 3.0, Technical Evaluation, states the following:

The fixed emergency lighting system is powered from vital buses. Upon loss of the normal power supply to the vital buses, the emergency diesel generators will provide power to the vital buses. Thus, the emergency lighting system will be continuously energized to the fire areas listed in table 2 of this SE.

6.2 Why NRC Safety Evaluation Needs Correction

The statement as written in the SE is incorrect. Fixed emergency lighting units with self-contained battery backup power are not powered from vital buses. The primary power source for the fixed, battery backup emergency lighting units is from normal lighting circuits that are fed from the non-Class IE auxiliary system. The area above the main control board and operators console are provided with light fixtures supplied from a Class 1E battery through a normally deenergized contactor. The contactor control circuit monitors the normal AC lighting feed and automatically energizes the fixtures from Class IE battery upon loss of AC power. Additionally, Table 2 in the SE does not list any fire areas. Table 2 instead lists component asset numbers. The SE is not consistent with, nor does it adequately disposition the docketed information provided in the Wolf Creek LAR.

7.0 Original Wolf Creek Request from LAR (Comment 7)

Section E.9.2 of WIP-E-1F9900-010-A-1 identifies the strategy that will be applied for fixed emergency lighting units (excluding those listed in Table E.2.5-1) as follows:

With limited exception, the fixed emergency lighting (excluding Table E.2.5-1) that was previously credited for illuminating operator manual actions will remain installed within the

Attachment I to ET 23-000163 Page 7 of 11

plant. The E-1L8900 identified head lamp aiming positions will be retained. However, this fixed emergency lighting, which will be treated comparable to life safety emergency lighting from a battery life (1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ) and preventive maintenance perspective, is considered supplemental to portable lighting. This lighting and the remaining 1.5-hour fixed emergency lighting will support firefighting efforts and life safety access/aggress.

7.1 NRC Safety Evaluation Discussion

SE, Section 3.0, Technical Evaluation, states the following:

The NRC staffs RAI requested information concerning the performance of regular maintenance on emergency light fixtures that would no longer be required to illuminate safe shutdown equipment or access/egress paths.

7.2 Why NRC Safety Evaluation Needs Correction

The statement as written in the SE is incorrect. The request for additional information (RAI) to Wolf Creek on 12/27/2022, documented via ML22361A005, does not include a RAI concerning the performance of regular maintenance on emergency light fixtures that would no longer be required to illuminate safe shutdown equipment or access/egress paths. The SE is not consistent with the docketed information associated with RAIs for the Wolf Creek LAR.

8.0 Original Wolf Creek Request from LAR (Comment 8)

As identified in Comment 1, the LAR did not request approval for portable lighting to specific fire areas.

8.1 NRC Safety Evaluation Discussion

In multiple locations within the SE and in the transmittal letter, the terms in certain fire areas, or in certain areas where were interjected when discussing portable lighting as the primary emergency lighting means for illuminating implementing procedures, safe shutdown equipment, and the respective access egress routes to the equipment.

8.2 Why NRC Safety Evaluation Needs Correction

This NRC statement is vague and vulnerable to misinterpretation. Therefore, Wolf Creek requests that this wording be corrected to avoid future confusion for the station and for the NRC. The original LAR requested a deviation from USAR Appendix 9.5E, 10 CFR Part 50 Appendix R Comparison, allowing the use of portable lighting as the primary emergency lighting means (with limited exceptions) for illuminating safe shutdown equipment and access egress routes to the equipment. The SE is not consistent with nor does it adequately disposition the docketed information provided in the Wolf Creek LAR.

Attachment I to ET 23-000163 Page 8 of 11

9.0 Original Wolf Creek Request from LAR (Comment 9)

There was no corresponding Wolf Creek statement as claimed by the NRC in Section 3.1 of the SE.

9.1 NRC Safety Evaluation Discussion

SE, Section 3.1, NRC Staff Evaluation states the following:

The licensee stated that the defense-in-depth elements are maintained (i.e., control of transient combustible materials), through the implementation of administrative procedures, automatic fire detection and fire suppression systems are provided as required by the fire hazard analysis, portable fire extinguishers and fire hose stations are provided throughout the plant for manual firefighting, and passive fire barrier features (walls, floors/ceilings, fire dampers, doors, penetration seals, fire wrap, and structural steel fireproofing) separating redundant post-fire safe-shutdown components are installed in accordance with industry standards and fire tested assemblies.

9.2 Why NRC Safety Evaluation Needs Correction

The above statement is true for the Wolf Creek Fire Protection Program. However, Wolf Creek did not state what the NRC claims it provided in the LAR or RAI response. Wolf Creek did not provide the defense-in-depth statement refenced discussed in Section 3.1 of the SE. Therefore, indicating that The licensee stated is incorrect, and the SE should be corrected for accuracy.

10.0 Original Wolf Creek Request from LAR (Comment 10)

Wolf Creek did not make the statements referenced by the NRC in its SE discussion regarding delineating building locations where safe shutdown equipment is located.

10.1 NRC Safety Evaluation Discussion

SE, Section 3.0, Technical Evaluation, states the following:

The equipment needed for safe shutdown at Wolf Creek is maintained inside the main power block and several buildings onsite.

10.2 Why NRC Safety Evaluation Needs Correction

Wolf Creek did not delineate the building locations where safe shutdown equipment is located.

The essential service water pumphouse is the only building remote from the main power block that contains safe-shutdown equipment. The SE should be corrected for accuracy.

Attachment I to ET 23-000163 Page 9 of 11

Comment on Markups Provided in Attachment II

Attachment II of this correspondence provides a proposed markup of the SE with recommended wording to address the provided comments and to support the correction of the SE. Additionally, the table provided on the next two pages summarizes the affected sections, paragraphs, and specifically relates the markup to the previously illustrated comments. Comments on the markups to provide clarity are also listed as necessary.

Attachment I to ET 23- 000163 Page 10 of 11

Affected Paragraph # Addresses Affected Section # / Table # Type Attachment I Comment Comment #

Cover Letter 2 Delete 8

1.0 1 Delete 8

2.1 3 Insert 2.1 5 Proposed change is 3.0 1 Insert None consistent with LAR Section 2 Detailed description.

3.0 1 Delete 8 Consistent with LAR Section 2 and Table E.2.5-1 from Enclosure 1 (WIP-E-1F9900-010-3.0 1 Insert 3.1 1, 4, 8 A-1). Table 1 and Table 2 was deleted.

Table 2 was renamed Table 1 and was provided in Insert 3.1 due to other changes.

3.0 2 Insert 3.2 10

3.0 3 Insert 3.3 2

3.0 2 Insert 10

3.0 Table 1 Delete 2

3.0 4, Table 2 Delete (Ref. Insert 3.1) 4

3.0 Table 2 continued Delete (Ref. Insert 3.1) 4

3.0 5 Delete 6 Consistent with LAR 3.0 6 Delete None Section 2 Detailed Description.

Consistent with LAR 3.0 6 Insert None Section 2 Detailed Description.

3.0 7 Delete 7

3.0 7 Insert None Editorial

Attachment I to ET 23- 000163 Page 11 of 11

Affected Paragraph # Addresses Affected Section # / Table # Type Attachment I Comment Comment #

3.0 8 Insert None Aligns with RAI response.

3.0 8 Insert None Editorial

3.0 8 Delete 8

3.1 1 Delete 3

3.1 2 Insert 1,4

3.1 2 Delete 2

3.1 3 Insert 9

3.1 3 Delete 2 Consistent with E.6 through E.12 of 3.1 4, 5 Insert 3.4 1,2 Enclosure 1 (WIP-E-1F9900-010-A-1) of the LAR.

Proposed conclusion statement based on 3.2 1 Insert 3.5 None information added to the SE from Enclosure 1 (WIP-E-1F9900-010-A-1) of the LAR.

Attachment II to ET 23- 000163 Page 1 of 14

Markup of Safety Evaluation Provided in Reference 4 Attachment II to ET 23-000163 Page 2 of 14

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

August 31, 2023

Mr. Cleveland Reasoner Chief Executive Officer and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION, UNIT 1 - ISSUANCE OF AMENDMENT NO. 237 RE: REQUEST FOR DEVIATION FROM FIRE PROTECTION REQUIREMENTS (EPID L-2022-LLA-0107)

Dear Mr. Reasoner:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 237 to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station, Unit 1. The amendment consists of changes to the renewed facility operating license and the Updated Safety Analysis Report (USAR) in response to your application dated August 2, 2022, as supplemented by letters dated January 26, and August 8, 2023.

The amendment revises License Condition 2.C.(5)," Fire Protection (Section 9.5.1, SER [Safety Evaluation Report], Section 9.5.1.8, SSER [Supplement to SER] #5)," and the USAR to allow the use of hard hat mounted portable lights as the primary emergency lighting means in certain fire areas for illuminating safe shutdown equipment, and access and egress routes to the equipment.

Attachment II to ET 23-000163 Page 3 of 14

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

RELATED TO AMENDMENT NO. 237 TO

RENEWED FACILITY OPERATING LICENSE NO. NPF-42

WOLF CREEK NUCLEAR OPERATING CORPORATION

WOLF CREEK GENERATING STATION, UNIT 1

DOCKET NO. 50-482

1.0 INTRODUCTION

By letter dated August 2, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No.ML22215A000), as supplemented by letters dated January 26, and August 8, 2023 (ML23026A359 and ML23220A422, respectively), Wolf Creek Nuclear Operating Corporation (the licensee) submitted a license amendment request (LAR) for the Wolf Creek Generating Station, Unit 1 (Wolf Creek), in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, "Application for amendment of license, construction permit, or early site permit," requesting changes to the fire protection License Condition 2.C.(5), "Fire Protection (Section 9.5.1, SER [Safety Evaluation Report],

Section 9.5. 1.8, SSER [Supplement to SER] #5)." The LAR proposed a deviation from the requirements of 10 CFR Part 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979. " Specifically, the licensee proposed a deviation from Wolf Creek Updated Safety Analysis Report (USAR), Appendix 9.5E, "10 CFR Part 50, Appendix R Comparison" (ML22151A150), to allow the use of hard hat mounted portable lights as the primary emergency lighting means in certain fire areas for illuminating safe shutdown equipment, and access and egress routes to the equipment in lieu of meeting the requirements of 10 CFR Part 50, Appendix R, Section 111.J, "Em

The supplemental letters dated January 26, and August 8, 2023, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on October 4, 2022 (87 FR 60217).

2.0 REGULATORY EVALUATION

2.1 Program Description and Regulatory Requirements

The regulations in 10 CFR 50.48(a), require that each operating nuclear power plant have a fire protection plan which satisfies Criterion 3, "Fire protection, " of Appendix A to 10 CFR Part 50,

"General Design Criteria for Nuclear Power Plants." Specific fire protection features deemed

Enclosure 2 Attachment II to ET 23-000163 Page 4 of 14

necessary to ensure this capability are delineated in Appendix R to 10 CFR Part 50. Criterion 3 of Appendix A to 10 CFR Part 50, requires, in part, that "[s]tructures, systems, and components

[SSCs] important to safety shall be designed and located to minimize,... the probability and effect of fire and explosions. " It further requires that the "[f]irefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the capability of these structures, systems, and components."

The regulations in 10 CFR Part 50, Appendix R establish fire protection features required to satisfy Criterion 3 of Appendix A to 10 CFR Part 50 with respect to certain generic issues for nuclear power plants licensed to operate prior to January 1, 1979. One of the principal objectives of the commercial nuclear power plant fire protection program is to ensure that the risk of fire-induced radiological hazards to the public, environment and plant personnel is minimized. To meet this objective, 10 CFR 50.48, "Fire protection," requires each operating nuclear power plant to have the means to limit fire damage to SSCs important to safety so that the capability to shut down the plant safely is ensured. The objective of safe shutdown of the plant is to assure that at least one means of achieving and maintaining safe shutdown capability is available during and after any postulated fire.

Wolf Creek was licensed to operate on June 4, 1985, and thus, is not subject to Appendix R to 10 CFR Part 50. However, the licensee committed to meet the requirements of Appendix R to 10 CFR Part 50, Section III.J to provide emergency lighting to assure safe shutdown capability is maintained during and after a fire. Appendix R to 10 CFR Part 50, Section III.J, states that, "E:meFgenoy lighting units with at least an 8 houF batter:y poweF supp ly sha ll be pFOYided in a ll areas needed for operation of safe shutdown equipment and in access and egress routes theFeto." The objeotiYe of this FequiFement is that in the eyent of a fiFe, adequate lighting will be --~--See Insert 2. 1 available to assure that the plant can be safely shut down.

The Wolf Creek operating license includes a fire protection license condition requiring the implementation of an approved fire protection program. License Condition 2.C.(5) allows the licensee to make changes to an approved fire protection program without prior NRC staff approval only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. All changes to the fire protection program must ensure that compliance is maintained with the requirements of 10 CFR 50.48(a).

2.2 Licensee 's Proposed Changes

The licensee's proposed changes would revise paragraph 2.C.(5)(a) of Renewed Facility Operating License NPF-42 and the fire protection program as described in the USAR for Wolf Creek.

The licensee proposes to revise License Condition 2.C.(5) by adding this current license amendment, as approved, to state (changes shown in bold):

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment 189, Amendment No. 191, Amendment No. 193, Amendment No. 205, Amendment No. 214, and Amendment No. 237, subject to provisions b and c below.

Attachment II to ET 23-000163 Page 5 of 14

Insert 2.1

Wolf Creek was licensed to operate on June 4, 1985, and thus, is not subject to Appendix R to 10 CFR Part 50. However, the licensee provided a design comparison response to Appendix R to 10 CFR 50, as documented in Appendix 9.5E of the Updated Safety Analysis Report (USAR). Appendix R to 10 CFR Part 50, Section III.J, states that, Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

The objective of this requirement is that in the event of a fire, adequate lighting will be available to assure that the plant can be safely shut down. The Wolf Creek comparison response to Appendix R to 10 CFR Part 50, Section III.J, was: The Power block complies.

As stated in USAR Section 9.5.3.2.3, emergency lighting units with eight-hour batteries are located in all plant areas required for operation of safety shutdown equipment and also those areas necessary for access and egress. The ESW pumphouse also complies.

Attachment II to ET 23-000163 Page 6 of 14

3.0 TECHNICAL EVALUATION

, w ith limited exception,

In its LAR dated August 2, 2022, the licensee requested a deviation from certain technical requirements of 10 CFR Part 50, Appendix R, Section III.J (as documented in Appendix 9.5E of the Wolf Creek USAR). Specifically, the licensee requested the use of hard hat mounted portable lights in certain fire areas as the primary emergency lighting means for illuminating

[ implementing procedures, safe shutdown equipment, and the respective access egress routes

!Delete I all to the equipment in support of post-fire safe shutdown or a non-fire event resulting in the loss of AC power. The licensee's proposed changes would replace the requirement of meeting the 8-hour fixed emergency lighting requirements of 10 CFR Part 50, Appendix R, Section III.J,_______ ~<::__----~!I nsert 3.1 referenced in Appendix 9.5E of the Wolf Creek USAR in certain fire areas.

The equipment needed for safe shutdown at Wolf Creek is maintained inside the main power block and several buildings onsite. Fixed emergency lighting is provided inside these buildings for areas needed for operation of safe shutdown equipment, as well as for access and egress routes in accordance with 10 CFR Part 50, Appendix R, Section llI.J.

The licensee requested to use hard hat mounted portable lights as an alternative for fixed emergency lighting units in the fire areas listed in table 1 of this safety evaluation (SE), where operator manual actions are performed.

the essential service water pumphouse. Tab le 1 Hard Hat Mounted Lighting Locations (identified in the LAR enc losure ~<-----1I Delete 1)

Fire Area Location A-16 A r G-48

~

G-aG

Fixed emergency lighting units with 8-hour battery capacity that will continue to be credited in the emergency lighting illumination response strategy for safe shutdown are listed in table 2 of this SE.

T b l 2 8 H a e our mergency IQ IAQ ocaIons L. hf L t' I en 11e IA ' a e f d H d

Lt R t b l E 2 a 1 ~

Delete (Ref

-- jAsset Location Insert 3.1) I QDC036 Control Room Equipment Cabinet Area ~

QDC037 Control Room QDC038 Control Room QDC039 Control Room QDC040 Control Room QDC057 I QDC067 Control Room Equipment Cabinet Area QDC060 I QDC061 Control Room Shift Manager's Q#ice

1The body of the text in the LAR states that the hard hat mounted lighting and the 8-hour emergency lighting locations are identified in Enclosure 1 but the enclosure itself doesn 't include the " 1."

Attachment II to ET 23-000163 Page 7 of 14

Insert 3.1

,with a diverse strategy comprised of the following:

8-hour fixed battery units for the locations that may require long term attendance in support of safe shutdown. These locations are identified in Enclosure 1, Table E.2.5-1 of the LAR. These locations are repeated in Table 1 below.

Table 1 Hour Emergency Lighting Locations (identified in LAR table E.2.5-1 1)

Asset Location QDC036 Control Room Equipment Cabinet Area QDC037 Control Room QDC038 Control Room QDC039 Control Room QDC040 Control Room QDC057 I QDC067 Control Room Equipment Cabinet Area QDC060 I QDC061 Control Room Shift Managers Office QDT018 Comm Corridor - Operations Hard Hat Rack QDA053 Auxiliary Shutdown Panel Room QDC046 A Emergency Diesel Generator Control Panel KJ121 QDC047 A Emergency Diesel Generator Panel NE107 QDC048 A Emergency Diesel Generator Panel NG03D QDC052 B Emergency Diesel Generator Panel KJ122 and NE1 06 QDC053 B Emergency Diesel Generator Panel NE106 QDC054 B Emergency Diesel Generator Panel NG04D

Portable (hard hat mounted) lighting for illuminating implementing procedures, safe shutdown equipment, and the access and egress routes to the equipment. This will be the primary emergency lighting method for most locations, which encompasses the following implementing procedures:

o OFN RP-017, Control Room Evacuation o OFN KC- 016, Fire Response o EMG C-0, Loss of All AC Power o OFN NB-034, Loss of All AC Power - Shutdown Conditions

1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months fixed battery units for firefighting activities, life safety access and egress, and supplementary lighting to portable lighting.

Attachment II to ET 23-000163 Page 8 of 14

Insert 3.2 Historically, the fixed emergency lighting provided inside these buildings for areas needed for operation of safe shutdown equipment, as well as for access and egress routes had been credited to satisfy the requirements of 10 CFR Part 50, Appendix R, Section llI.J.

Insert 3.3 support of post-fire safe shutdown or a non-fire event resulting in the loss of all AC power for all plant fire areas where operator manual actions (OMAs) are performed, with the exception of the fixed emergency lighting locations identified in Table 1.

Attachment II to ET 23-000163 Page 9 of 14 Delete (Ref. Insert 3. 1)

QDT018 QDA053 Auxiliary Shutdown Panel Room QDG046 A QDG047 A QDG048 A QDC052 QDC053 QDC054

The fixed emergency lighting system is powered from vital buses. Upon loss of the normal power supply to the vital buses, the emergency diesel generators will provide power to the vital buses. Thus, the emergency lighting system will be continuously energized to the fire areas listed in table 2 of this SE.

Section III.J of Appendix R to 10 CFR Part 50, requires plants that are required to provide self-contained 8-hour battery-backed emergency lighting to illuminate the location of operator actions and access and egress routes thereto to perform operator manual actions credited for safe shutdown. The LAR credits the use of hard hat mounted portable lights in certain ---~

applications as the primary emergency lighting means for illuminating implementing procedures, ft--'-------------------il (w ith li~ited I safe shutdown equipment, and the respective access and egress routes to the equipment in. exceptions).

support of post-fire safe shutdown or a non-fire event resulting in the loss of AC power. In the A-,-----~

LAR, the licensee stated that Wolf Creek continues to maintain a deterministic fire protection license basis, with no plans to transition to a risk-informed, performance-based fire protection licensing basis (i.e., National Fire Protection Association (NFPA) Standard 805, "Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," or 10 CFR 50.48(c)).

Based on its review of information in the LAR, the NRC staff provided a request for additional ~

information (RAI) to the licensee on December 27, 2022 (ML22361A005). The NRG staff's R/\\I i/,

requested information concerning the performance of regular maintenance on emergency light

~,-------------, ff's fixtures that would no longer be required to illuminate safe shutdown equipment or access/egress paths. Furthermore, the NRC sta RAI requested information regarding the status of updating the feasibility and reliability review for each fire area where operator manual actions are conducted since it did not appear to the NRC staff that this review had been updated for fires to reflect the use of portable hard hat mounted lights in lieu of fixed emergency light fixtures.

outside the control room In its response to the RAI by letter dated January 26, 2023, the licensee provided an updated evaluation that evaluated operator manual actions using hard hat mounted lights as the primary -----'k--------____,§!J emergency lighting means in certain fire areas for illumination during safe shutdown implementing procedures, including the equipment, and respective access and egress routes to the equipment. The licensee stated that its evaluation concluded that the proposed change of ___ /&-_=-------------I Delete I crediting hard hat mounted portable lights in certain areas as the primary emergency lighting means does not adversely affect operator manual action implementation, uncertainty, or time margins.

In its response to the RAI, the licensee indicated that its evaluation determined that the post-fire operator manual actions for a fire outside the main control room continue to remain feasible and reliable demonstrating that the plant can be safely shutdown in the event of a fire. In addition, the licensee indicated that the performance of the operator manual actions in support of applicable procedures will not be adversely affected by the use of hard hat mounted portable Attachment II to ET 23-000163 Page 10 of 14

lights as the primary emergency lighting means. The licensee further indicated that for life safety access, egress, and for firefighting activities, 1.5-hour fixed lights will be available for supplementary lighting to the portable lights.

The licensee response to the RAI provided additional information the NRC staff needed to complete its review.

3.1 NRC Staff Evaluation

The underlying purpose of 10 CFR Part 50, Appendix R, Section Ill.J, is to ensure that adequate lighting is available to aid the operator for an extended period of time during plant fire emergencies. In plant areas, where installation of 8-hour battery backup supplied lighting is not achievable, the hard hat mounted portable lights accomplish the purpose of achieving adequate emergency lighting because they will ensure that adequate lighting is available to aid the as the primary operator for an extended period of time during plant fire emergencies. emergency lighting means (with the The licensee's proposed change would allow Wolf Creek to use hard hat mounted portable exception of the 8-

I/

lights in certain fire areas in conjunction with the other installed fire protection features, to hour fixed ensure the proper illumination of implementing procedures, safe shutdown equipment, and emergency lights access and egress routes to the equipment, in lieu of meeting the requirements of identified in Table 10 CFR Part 50, Appendix R, Section III.J, for 8-hour fixed emergency light fixture. The areas 1 ),

are listed in table 1 of this SE, and include fire areas A-16, C-18, C-21, C-22, C-23, C-24, C-30, and C-33.

The licensee stated that the defense-in-depth elements are maintained (i.e., control of transient Standard combustible materials), through the implementation of administrative procedures, automatic fire fire detection and fire suppression systems are provided as required by the fire hazard analysis, protection portable fire extinguishers and fire hose stations are provided throughout the plant for manual firefighting, and passive fire barrier features (walls, floors/ceilings, fire dampers, doors, penetration seals, fire wrap, and structural steel fireproofing) separating redundant post-fire safe-shutdown components are installed in accordance with industry standards and fire tested assemblies. Therefore, fire areas A-16, C-18, C-21, C-22, C-23, C-24, C-30, and C-33 provide a level of safety that results in the unlikely occurrence of fires; rapid detection, control, and

~

extinguishment of fires that do occur, and the protection of SSCs important to safety.

In addition, the licensee has provided preventative and protective measures in addition to f.easible and reliable operator manual aotions that together demonstrate the lioensee's ability to preserve or maintain safe shutdown capability at Wolf Creek in the event of a fire in the identified fire areas. An action is considered feasible if it is shown that it is possible to be performed within the available time (considering relevant uncertainties in estimating the time available). An action is considered to be reliable as well if it is shown that it can be dependably and repeatedly performed within the available time, by different crews, under somewhat varying conditions.

Insert 3.4 Based on its review of the information provided by the licensee, the NRC staff concluded that, in the event of a fire, the use of hard hat mounted portable lights in the fire areas listed in table 1 of this SE, will provide sufficient illumination to enable safe shutdown of the plant because the licensee has demonstrated that the actions remain feasible and reliable with the use of the hard hat mounted portable lights.

Attachment II to ET 23-000163 Page 11 of 14

Insert 3.4

The evaluation of the emergency lighting strategy documented in Enclosure 1 (Attachment E of WIP-E-1F9900- 010-A-1), adequality evaluates the acceptability of the portable lighting as an alternative to fixed emergency lighting. The evaluation details the following:

Portable Lighting Selection

A commercially available, robust, high lumen output headlamp with an option for disposable or long life rechargeable battery application was selected as the portable, hard hat mounted light of choice.

Demonstration

Detailed field testing of the portable lighting revealed that it has a greater lumen level and beam that is wider and longer than the 8-hour fixed emergency lighting units utilized in the plant. The rechargeable battery was also demonstrated to have a longer life than the 8-hour fixed emergency lighting.

Preventive Maintenance Activities

The headlamp assembly will be standard issue to all on shift Operations personnel responsible for manipulating plant equipment. It will be attached to their hard hat and used in situations where plant activities require additional illumination to safely perform their job function. Each Operator will be responsible for proper operation and upkeep of the headlamp, including battery charge status and battery replacement. Information regarding headlamp responsibilities and upkeep will be provided in a Standing Order, Desktop Instruction, or equivalent. There will be no formal preventive maintenance activity for the individual headlamps issued to Operations personnel.

Sufficient replacement batteries and spare portable headlamps are strategically located in the plant, and periodically inventoried, to ensure that a minimum eight hours of portable lighting is available for Operations staff personnel responsible for the manipulation of safe shutdown equipment.

Spare hardhats with portable lighting will also be provided in the control room.

Defense-in-depth consideration

The licensee identified that the Table 1 fixed emergency lights will continue to be credited as 8-hour battery capacity for the control room, auxiliary shutdown panel, and emergency diesel generator control panel areas. This is in recognition that these areas may warrant continuous manning in response to potential postulated events, such as fire or loss of offsite power. It is prudent to retain the current emergency lighting strategy for these areas in an effort to promote human factoring, since there are many indications and controls in these areas that require Operator attention. Also, the emergency lighting unit illuminating the Operations hard hat rack Attachment II to ET 23-000163 Page 12 of 14

just outside the control room (QDT018 in Table 1) will be credited as an 8-hour emergency light to ensure illuminated access/egress for control room personal to obtain their hard hats, containing the portable headlamp.

Feasibility and Reliability Analysis

Feasibility and reliability is evaluated considering NUREG-1852 guidance in support of OMA implementation for fires outside the control room, control room evacuation due to fire, and non-fire events.

Future Evaluation of Equivalent Portable Lighting

The analysis recognizes that obsolescence challenges and future advancements in portable lighting and batteries may result in a desire to utilize equivalent replacement portable lighting and/or batteries in lieu of the models discussed.

Adequate guidance is provided to ensure headlamp and/or battery replacements are equivalent and would not invalidate this evaluation.

Maintenance Rule Application

The 8-hour fixed emergency lighting identified in Table 1, will continue to be credited for illumination of safe shutdown operator actions. Considering this, these emergency lighting units will also continue to be scoped within the Wolf Creek 10 CFR 50.65 Maintenance Rule Program. The remaining fixed emergency lighting, which is being downgraded to 1.5 battery capacity, and the portable lighting (a readily replaceable tool), will not be included within the scope of the Wolf Creek 10 CFR 50.65 Maintenance Rule Program.

Based on its review of the information provided by the licensee, the NRC staff concluded that for OMA implementation, utilizing hard hat mounted portable lighting, as the primary emergency lighting means in a diverse emergency lighting strategy, provides reasonable assurance that safe shutdown of the plant is not adversely affected.

Attachment II to ET 23-000163 Page 13 of 14

3.2 NRC Staff Conclusion

On the basis of this evaluation, the NRC staff GORGludes that the liGeRsee's l9FOl90Sed ~ use of

hard hat mounted portable lights in lieu of 8-hour battery supplied emergency light fixtures in the fire areas described in table 1 of this SE, satisfy the underlying purpose of 10 CFR Part 50, Appendix R, Section Ill.J, to provide sufficient illumination to the areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

4.0 STATE CONSULTATION

In accordance with the Commission 's regulations, the Kansas State official was notified of the proposed issuance of the amendment on May 18, 2023. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, published in the Federal Register on October 4, 2022 (87 FR 60217), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's 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.

Principal Contributors: N. Iqbal, NRR J.Robinson, NRR

Date: August 31, 2023 Attachment II to ET 23-000163 Page 14 of 14

Insert 3.5 On the basis of this evaluation, the NRC staff concludes that the licensees proposed use of hard hat mounted portable lights as the primary emergency lighting means for OMA response to fire events, coupled with the 8-hour battery capacity emergency lighting units identified in Table 1, satisfies the underlying purpose of 10 CFR Part 50, Appendix R, Section Ill.J, to provide sufficient illumination to the areas needed for operation of safe shutdown equipment and in access and egress routes thereto. The use of hard hat mounted portable lights as the primary emergency lighting means for OMA response to non-fire events resulting in a loss of all AC power is also determined acceptable by the NRC staff, as the evaluation for OMA response for fire events is bounding.

Attachment III to ET 23- 000163 Page 1 of 1 6

Safety Evaluation with Markups Incorporated (Clean Pages)

LETTERHEAD REMOVED

Month DD, YYYY

Mr. Cleveland Reasoner Chief Executive Officer and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION, UNIT 1 - ISSUANCE OF AMENDMENT NO. 237 RE: REQUEST FOR DEVIATION FROM FIRE PROTECTION REQUIREMENTS (EPID L-2022-LLA-0107)

Dear Mr. Reasoner:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 237 to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station, Unit 1. The amendment consists of changes to the renewed facility operating license and the Updated Safety Analysis Report (USAR) in response to your application dated August 2, 2022, as supplemented by letters dated January 26, and August 8, 2023.

The amendment revises License Condition 2.C.(5), Fire Protection (Section 9.5.1, SER [Safety Evaluation Report], Section 9.5.1.8, SSER [Supplement to SER] #5), and the USAR to allow the use of hard hat mounted portable lights as the primary emergency lighting means for illuminating safe shutdown equipment, and access and egress routes to the equipment.

C. Reasoner

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

SIGNATURE REMOVED

Docket No. 50-482

Enclosures:

1. Amendment No. 237 to NPF-42

2. Safety Evaluation

cc: Listserv LETTERHEAD REMOVED

WOLF CREEK NUCLEAR OPERATING CORPORATION

WOLF CREEK GENERATING STATION, UNIT 1

DOCKET NO. 50-482

AMENDMENT TO RENEWED FACILITY OPERATING LICENSE

Amendment No. 237 License No. NPF-42

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Wolf Creek Generating Station, Unit 1 (the facility) Renewed Facility Operating License No. NPF-42 filed by the Wolf Creek Nuclear Operating Corporation (the Corporation), dated August 2, 2022, as supplemented by letters dated January 26, and August 8, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is hereby amended as indicated in the attachment to this license amendment, and paragraph 2.C.(5) of Renewed Facility Operating License No. NPF-42 is hereby amended to read, in part, as follows

(5) Fire Protection (Section 9.5.1, SER Section 9.5.1.8, SSER #5)

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment 189, Amendment No. 191, Amendment No. 193, Amendment No. 205, Amendment No. 214, and Amendment No. 237, subject to provisions b and c below.

In addition, by Amendment No. 237, Renewed Facility Operating License No. NPF 42 is hereby amended to authorize revision to the Updated Safety Analysis Report (USAR) as set forth in the licensees application dated August 2, 2022, as supplemented by letters dated January 26, and August 8, 2023, and evaluated in the NRC staffs safety evaluation associated with this amendment. The licensee shall submit the update of the USAR authorized by this amendment in accordance with 10 CFR 50.71(e).

3. The license amendment is effective as of its date of issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

SIGNATURE REMOVED

Attachment:

Changes to the Renewed Facility Operating License

Date of Issuance:

ATTACHMENT TO LICENSE AMENDMENT NO. 237 TO

RENEWED FACILITY OPERATING LICENSE NO. NPF-42

WOLF CREEK GENERATING STATION, UNIT 1

DOCKET NO. 50-482

Replace the following page of Renewed Facility Operating License No. NPF-42 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Renewed Facility Operating License

REMOVE INSERT

5 5

5

(5) Fire Protection (Section 9.5.1, SER, Section 9.5.1.8, SSER #5)

(a) The Operating Corporation shall maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 17, the Wolf Creek site addendum through Revision 15, as approved in the SER through Supplement 5, Amendment 189, Amendment No. 191, Amendment No. 193, Amendment No. 205, Amendment No. 214, and Amendment No. 237, subject to provisions b and c below.

(b) The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(c) Deleted.

(6) Qualification of Personnel (Section 13.1.2, SSER #5, Section 18, SSER

1)