WO 12-0035, Application for License Amendment to Revise Technical Specification 3.6.6, Containment Spray and Cooling Systems

Application for License Amendment to Revise Technical Specification 3.6.6, Containment Spray and Cooling Systems

ML12132A050
Person / Time
Site:	Wolf Creek
Issue date:	05/02/2012
From:	Hedges S Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WO 12-0035
Download: ML12132A050 (19)

Text

W0LF CREEK NUCLEAR OPERATING CORPORATION Stephen E. Hedges May 2, 2012 Site Vice President WO 12-0035 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: Application To Revise Technical Specification 3.6.6, "Containment Spray and Cooling Systems" Gentlemen:

Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS). The proposed amendment replaces the ten-year surveillance Frequency for testing the containment spray nozzles in accordance with Technical Specification (TS)

Surveillance Requirement (SR) 3.6.6.8 with an event-based Frequency.

Attachment I provides a description of the proposed change and supporting technical evaluation. Attachment II provides the existing TS pages marked up to show the proposed change. Attachment III provides revised (clean) TS page. Attachment IV provides the existing TS Bases page marked up to show the proposed changes and is for information only. Final TS Bases changes will be implemented pursuant to TS 5.5.14, "Technical Specification (TS) Bases Control Program," at the time the amendment is implemented.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." Pursuant to 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Section (b),

no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The Plant Safety Review Committee reviewed this amendment application. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this amendment application, with attachments, is being provided to the designated Kansas State official.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET iJ(LA'L

WO 12-0035 Page 2 of 3 WCNOC requests approval of the proposed amendment by January 10, 2013, which would eliminate the requirement to perform the fixed Frequency surveillance test on the containment spray nozzles during Refueling Outage 19.

Refueling Outage 19 is currently scheduled to commence on February 4, 2013. It is anticipated that the license amendment, as approved, will be effective upon issuance and will be implemented within 90 days from the date of issuance.

This letter contains no commitments.

If you have questions concerning this matter, please contact me at (620) 364-4190 or Mr. Gautam Sen at (620) 364-4175.

Sincerely, Ste e E. Hedges SEH/rlt Attachments:

IV Ill IV Evaluation Proposed Technical Specification Change (Markup)

Revised Technical Specification Page Proposed Technical Specification Bases Changes (For Information Only) cc:

E. E. Collins (NRC), w/a T. A. Conley (KDHE), w/a J. R. Hall (NRC), w/a N. F. O'Keefe (NRC), w/a Senior Resident Inspector (NRC), w/a

WO 12-0035 Page 3 of 3 STATE OF KANSAS

))ss COUNTY OF COFFEY )

Stephen E. Hedges, of lawful age, being first duly sworn upon oath says that he is Site Vice President 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_

Stephen E/ 00s Site Vice Pr s ent SUBSCRIBED and sworn to before me this I day of 71)tj

~L2aq2

,2012.

Notary Public Expiration Date f

1k2Jy2/A'gA/, ii; c26~/Y I

Attachment I to WO 12-0035 Page 1 of 9 EVALUATION

Subject:

Application To Revise Technical Specification 3.6.6, "Containment Spray and Cooling Systems" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusion

6.0 REFERENCES

Attachment I to WO 12-0035 Page 2 of 9 EVALUATION 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS). The proposed change revises the Technical Specifications (TS) for the Containment Spray System (Limiting Condition for Operation 3.6.6).

Current Surveillance Requirement (SR) 3.6.6.8 requires verification that each spray nozzle is unobstructed at a ten-year Frequency. The proposed change would revise the fixed ten-year Frequency with an event-based Frequency.

2.0 DETAILED DESCRIPTION The proposed change revises SR 3.6.6.8 as shown below:

SURVEILLANCE FREQUENCY SR 3.6.6.8 Verify each spray nozzle is unobstructed. yea-s Following maintenance which could result in nozzle blockage Performance of this Surveillance is currently limited to refueling outages. The proposed change will eliminate unnecessary testing of spray nozzles by requiring the test be performed following activities or conditions that could potentially cause nozzle blockage. The current Surveillance requires personnel to verify air flow at each spray nozzle located at high elevations inside containment.

The proposed change is expected to result in a reduction in personnel risk, radiation exposure, and outage costs associated with performing the test.

The changes to the affected TS Bases pages will be incorporated in accordance with TS 5.5.14, "Technical Specification (TS) Bases Control Program."

3.0 TECHNICAL EVALUATION

0

System Description

The Containment Spray System is an Engineered Safety Feature used in response to a postulated Loss of Coolant Accident (LOCA) or Main Steam Line Break (MSLB). In response to a LOCA or MSLB, the Containment Spray System is designed to:

Maintain reactor containment building pressure within design limits.

Reduce the quantity of airborne iodine.

Establish the sump pH to retain elemental iodine.

Attachment I to WO 12-0035 Page 3 of 9 These functions are performed by chemically treated water sprayed into the containment atmosphere through nozzles from spray headers located throughout the containment. The large spray drop surface-to-containment volume ratio enables the spray to effectively maintain containment building pressure and remove fission products from the containment.

Sodium hydroxide entrained in the spray flow establishes the proper sump pH to ensure the retention of elemental iodine. A major benefit of the Containment Spray System is removal of iodine from the containment atmosphere. Radioiodine in its various forms is a fission product of primary concern in evaluating the consequences of a LOCA.

The Containment Spray System consists of two separate trains of equal capacity each independently capable of meeting the design bases. Each train includes a containment spray pump, spray header and nozzles, spray additive eductor, valves, and the necessary piping, instrumentation, flushing connections, and controls.

The two Containment Spray System pumps are the vertical centrifugal type, driven by electric induction motors. These pumps are designed to provide sufficient flow into containment during accident conditions to both cool the containment atmosphere and remove radioactive iodine. One of the two trains is capable of providing 100% of the required water and sodium hydroxide flow to the spray headers mounted throughout the containment.

Each train, by itself, will also provide 100% of the required containment spray volume coverage.

Spray headers are located in the domed roof of the containment building, providing 360-degree coverage over the containment volume. The spray headers are located as high as possible without interruption of the spray pattern by impingement on the inside of the containment dome.

Piping to the spray headers assures delivery of 100% of the required spray flow assuming any single active failure. Each containment spray header contains 197 hollow cone nozzles, each capable of providing a design flow of 15.2 gpm.

The Containment Spray System is actuated either automatically by a containment High-3 pressure signal or manually.

An automatic actuation opens the containment spray pump discharge valves, starts the two containment spray pumps and begins the injection phase. A manual actuation of the Containment Spray System requires the operator to simultaneously actuate two separate switches on the main control board to begin the same sequence. The injection phase continues until a refueling water storage tank (RWST) level Low-Low alarm is received. The Low-Low level alarm for the RWST signals the operator to manually align the system to the recirculation mode. The Containment Spray System in the recirculation mode maintains an equilibrium temperature between the containment atmosphere and the recirculated sump water. Operation of the Containment Spray System in the recirculation mode is controlled by the operator in accordance with the emergency operating procedures.

Performance History Testing Preoperational testing of the Containment Spray System verified the operational parameters of the spray pumps during recirculation to the RWST. This testing verified the proper sequencing of valves and pumps occurs on initiation of the Containment Spray System and demonstrated the proper operation of remotely operated valves. This testing also demonstrated that the spray nozzles in the containment spray header are clear of obstructions by passing air through them, utilizing test connections. Testing of the spray nozzles by the manufacturer has verified that they will function as predicted, in terms of flow rate, spray angle, drop size spectrum, and mean drop size as a function of the pressure drop across the nozzles.

Attachment I to WO 12-0035 Page 4 of 9 Periodic in-place air flow tests through the spray nozzles have been conducted at the interval specified in the TSs. The spray nozzles for WCGS were initially tested at five-year intervals. As approved by the Nuclear Regulatory Commission (NRC) in License Amendment No. 86 (Reference 6.1) the surveillance interval is currently ten years.

Test Performance Date Pre-Operational 03/08/85 TS Surveillance (5 year interval) 04/04/1990 TS Surveillance (10 year interval) 04/08/2002 The results of each test demonstrated unobstructed flow through each nozzle. These tests confirmed that the nozzles are free from construction debris, and also free from obstructions that could have occurred following startup and operation of the plant. Also, the tests show that the spray nozzles did not become obstructed over a period of normal reactor operation.

Maintenance and Modification A review of the maintenance and modification history indicates that a number of work orders and modifications have been implemented on the Containment Spray System since the last air flow test including installation of a recirculation line on the Containment Spray System piping line to allow full flow pump testing. However, there has been no maintenance or modification to the system that would have potentially impacted the spray headers and nozzles.

Foreign material exclusion and cleanliness control practices, including post-work inspections, minimize the intrusion of foreign material into the Containment Spray System spray headers and nozzles.

0 Nozzle Blockage Mechanisms The Containment Spray System header and nozzles are passive devices that are not normally exposed to fluids or debris. The system piping and nozzles are fabricated of stainless steel, which is highly resistant to corrosion, especially in a low-stress application such as at WCGS.

Conditions for stainless steel corrosion, i.e., stress, temperature, and chlorides, are not present.

The WCGS spray ring headers are maintained dry. Standing water is present in system piping up to the normally closed containment isolation valves.

Formation of significant corrosion products is unlikely because the components are stainless steel. Therefore, the nozzles are unlikely to become obstructed due to corrosion.

NRC Generic Letter 93-05 (Reference 6.2), described a problem at San Onofre Unit 1 that was caused because sodium silicate, a coating material applied to the Containment Spray System carbon steel piping, clogged seven nozzles. The WCGS Containment Spray System piping and nozzles are stainless steel and are not coated. Therefore, that concern is not applicable to the WCGS.

In developing NUREG-1 366 (Reference 6.3), NRC staff reviewed industry experience regarding issues identified during spray nozzle testing and found that the only problems in pressurized water reactor Containment Spray Systems were those involving construction errors.

The Containment Spray System nozzles for WCGS have been tested satisfactorily three times since completion of construction, demonstrating that the construction problems identified in NUREG-1366 do not exist at WCGS.

Attachment I to WO 12-0035 Page 5 of 9 0

Foreign Material Exclusion The Foreign Material Exclusion program at WCGS is governed by procedure AP 12-003, "Foreign Material Exclusion." The procedure provides the program controls and guidelines for establishing requirements to prevent the introduction of foreign material, e.g., dirt, debris, and tools, into open systems, structures, and components.

The procedure establishes the administrative structure, requirements, and expectations that define processes and guide workers behaviors regarding foreign material control.

The procedure establishes foreign material exclusion guidelines, work control plans/processes, work practices, the use of barrier devices, inspection requirements, and guidance for recovery from loss of integrity relevant to the control of foreign materials. The WCGS Corrective Action Program is used when unexpected foreign material is found or introduced into an identified open foreign material exclusion controlled system, structure, or component. The WCGS Foreign Material Exclusion program prevents debris from remaining in the Containment Spray System piping, headers, and nozzles following maintenance, testing, or inspections which result in opening the system.

These administrative controls are considered to be sufficient to assure foreign material is excluded from open systems and components during maintenance and modification activities.

Therefore, the Foreign Material Exclusion program provides adequate assurance that debris or foreign material would not be left in the Containment Spray System that could prevent the system's ability to perform its specified safety function.

Due to their locations in the containment, introduction of foreign material into the spray headers is highly unlikely.

Foreign material introduced as a result of maintenance is the most likely cause for obstruction; therefore, verification during and following such maintenance would suffice to assure no material is introduced that could cause nozzle blockage.

As noted earlier, the probability of foreign material intrusion into the Containment Spray System spray headers and nozzles is very low. System configuration is such that introduction of foreign material through the nozzles is highly unlikely.

The Foreign Material Exclusion program provides for exclusion, identification, and retrieval of any foreign material introduced or identified within the Containment Spray System.

0 Conclusion This license amendment request proposes revising the containment spray nozzle surveillance (SR 3.6.6.8) to require verification that the nozzles are unobstructed following maintenance which could result in nozzle blockage. The Containment Spray System was demonstrated to be OPERABLE prior to initial plant startup. Since then, two successful air flow tests have been performed.

Additionally, the design of the system minimizes the likelihood of corrosion, degradation, or inadvertent introduction of foreign material that could adversely affect the Containment Spray System spray header flow. Industry experience indicates that maintenance activities are the most likely events that would introduce foreign material to cause nozzle blockage. WCNOC utilizes a Foreign Material Exclusion program during Containment Spray System maintenance or modifications that require opening the system. The revision to the surveillance requirement proposed by this license amendment requires verification of nozzle OPERABILITY if maintenance or modification activities could result in nozzle obstruction.

Attachment I to WO 12-0035 Page 6 of 9 Reduced testing is justified where operating experience has shown that routinely passing a surveillance test performed at a specified interval has no apparent connection to overall component reliability. In this case, routine surveillance testing at the specified frequency is not connected to any activity that may initiate reduced component reliability, and, therefore, is of limited value in ensuring component reliability. The design of the Containment Spray System, maintenance and testing history of the system, and foreign material exclusion controls provide reasonable assurance that the reduced surveillance Frequency will not impact the ability of the system to perform its specified function.

This license amendment request is submitted to revise SR 3.6.6.8 requirements prior to the next required verification during Refueling Outage 19. Refueling Outage 19 is currently scheduled to commence on February 4, 2013.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The regulatory bases and guidance documents associated with the proposed change discussed in this amendment application include:

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include Technical Specifications (TSs) as part of the operating license.

The TSs ensures the operational capability of structures, systems, and components that are required to protect the health and safety of the public. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(3),

"Surveillance requirements," defines surveillance requirements as requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

10 CFR 50 Appendix A, Criterion 38 -- Containment heat removal. A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.

10 CFR 50 Appendix A, Criterion 39 -- Inspection of containment heat removal system.

The containment heat removal system be designed to permit appropriate periodic inspection of important components, such as the torus, sumps, spray nozzles, and piping to assure the integrity and capability of the system.

10 CFR 50 Appendix A, Criterion 40 -- Testing of containment heat removal system.

The containment heat removal system be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole, and under conditions as close to the design as practical performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the associated cooling water system.

Attachment I to WO 12-0035 Page 7 of 9 The requested TS changes do not affect the ability to verify that spray nozzles are not obstructed. Although a calendar based periodic nozzle flow test would no longer be required, an event-or condition-based test requirement would provide reasonable assurance that the spray nozzles will perform their safety function.

Based on the above, WCNOC concludes that the proposed amendment is acceptable and complies with all the applicable regulatory requirements.

4.2 Precedent On June 1, 2011, the NRC issued Amendment Nos. 314 and 298 (Reference 6.4) for the Donald C. Cook Nuclear Plant, Units 1 and 2. The amendments revised the containment spray nozzles obstruction surveillance frequency specified in Surveillance Requirement 3.6.6.5 from a fixed "10 years" to "following maintenance that could result in nozzle blockage."

On August 24, 2010, the NRC issued Amendment No. 261 and 256 (Reference 6.5) for the Catawba Nuclear Station, Units 1 and 2. These amendments revise the TSs to allow testing containment spray nozzles for nozzle blockage following activities which could result in nozzle blockage, rather than a fixed periodic basis.

A review of the above amendment requests determined that the changes being proposed by WCNOC in this amendment request are sufficiently similar to those approved amendments to provide precedent for approval of this license amendment request.

The NRC staff has previously approved a number of similar license amendments. Examples include Amendment Nos. 126 and 126 for Braidwood Station, Units 1 and 2 (February 20, 2003, Accession No. ML022880596), Amendment Nos. 190 and 179 for Prairie Island Nuclear Generating Plant, Units 1 and 2 (November 6, 2008, Accession No. ML082740226), and Amendment No. 233 for Arkansas Nuclear One, Unit 1 (July 9, 2008, ML081540218).

4.3 No Significant Hazards Consideration Determination The proposed amendment revises the Technical Specifications (TS) for the Containment Spray System (Limiting Condition for Operation 3.6.6). Current Surveillance Requirement (SR) 3.6.6.8 requires verification that each spray nozzle is unobstructed at a ten-year Frequency.

The proposed change would revise the fixed ten-year Frequency with an event-based Frequency.

Wolf Creek Nuclear Operating Corporation has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No The Containment Spray System and its spray nozzles are not accident initiators and therefore, the proposed change does not involve a significant increase in the probability of an accident.

The revised surveillance requirement will require event-based Frequency verification in lieu of fixed Frequency verification. The proposed change does

Attachment I to WO 12-0035 Page 8 of 9 not have a detrimental impact on the integrity of any plant structure, system, or component that may initiate an analyzed event. The proposed change will not alter the operation or otherwise increase the failure probability of any plant equipment that can initiate an analyzed accident.

This change does not affect the plant design. There is no increase in the likelihood of formation of significant corrosion products.

Due to their location at the top of the containment, introduction of foreign material into the spray headers is unlikely. Foreign material introduced during maintenance activities would be the most likely source for obstruction, and verification following such maintenance would confirm the nozzles remain unobstructed. Since the Containment Spray System will continue to be available to perform its accident mitigation function, the consequences of accidents previously evaluated are not significantly increased.

Therefore, the consequences of an accident previously evaluated are not significantly affected by the proposed change.

2.

Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change will not physically alter the plant (no new or different type of equipment will be installed) or change the methods governing normal plant operation.

The proposed change does not introduce new accident initiators or impact assumptions made in the safety analysis. Testing requirements continue to demonstrate that the Limiting Conditions for Operation are met and the system components are functional.

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

3.

Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The system is not susceptible to corrosion-induced obstruction or obstruction from sources external to the system.

Maintenance activities that could introduce foreign material into the system would require subsequent verification to ensure there is no nozzle blockage.

The spray header nozzles are expected to remain unblocked and available in the event that the safety function is required. Therefore, the capacity of the system would remain unaffected. The proposed change does not relax any criteria used to establish safety limits and will not relax any safety system settings.

The safety analysis acceptance criteria are not affected by this change.

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

Attachment I to WO 12-0035 Page 9 of 9 Based on the above, Wolf Creek Nuclear Operating Corporation concludes that the proposed amendment does not involve a 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.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the 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.

5.0 ENVIRONMENTAL CONSIDERATION

WCNOC has reviewed the proposed amendment for environmental considerations. The review has determined that the proposed amendment would change requirements with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 Letter from J. C. Stone, USNRC, to N. S. Cams, WCNOC, 'Wolf Creek Generating Station - Amendment No. 86 to Facility Operating License No. NPF-42 (TAC NO.

M91862)," May 17, 1995.

6.2 Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation," September 27, 1993.

6.3 NUREG-1366, "Improvements to Technical Specification Requirements," December 1992.

6.4 Letter from P. S. Tam, USNRC, to L. J. Weber, Indiana Michigan Power Company, "Donald C. Cook Nuclear Plant, Units 1 and 2 -

Issuance of Amendments RE:

Containment Spray Nozzle Surveillance Requirement (TAC NOS. ME4125 and ME4126)," June 1,2011, (Accession No. ML11112A123).

6.5 Letter from J. Stang, USNRC, to J. R. Morris, Duke Energy Carolinas, "Catawba Nuclear Station, Units 1 and 2, McGuire Nuclear Station, Units 1 and 2, and Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments Regarding Performance Testing of Containment Spray Nozzles (TAC NOS. ME2497, ME2498, ME2499, ME2500, ME2501, ME2502 and ME2503)," August 24, 2010 (Accession No. ML100690007).

Attachment II to WO 12-0035 Page 1 of 2 ATTACHMENT II PROPOSED TECHNICAL SPECIFICATION CHANGE (MARKUP)

Attachment II to WO 12-0035 Page 2 of 2 Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.3 Not Used.

SR 3.6.6.4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equal to the Inservice the required developed head.

Testing Program SR 3.6.6.5 Verify each automatic containment spray valve in the 18 months flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.6.6.6 Verify each containment spray pump starts 18 months automatically on an actual or simulated actuation signal.

SR 3.6.6.7 Verify each containment cooling train starts 18 months automatically and minimum cooling water flow rate is established on an actual or simulated actuation signal.

SR 3.6.6.8 Verify each spray nozzle is unobstructed.

F F7,JJWtý WW-A COUIA Wolf Creek - Unit 1 3.6-18 Amendment No. 42-3, 167 I

Attachment III to WO 12-0035 Page 1 of 2 ATTACHMENT III REVISED TECHNICAL SPECIFICATION PAGE

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.3 Not Used.

SR 3.6.6.4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equal to the Inservice the required developed head.

Testing Program SR 3.6.6.5 Verify each automatic containment spray valve in the 18 months flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.6.6.6 Verify each containment spray pump starts 18 months automatically on an actual or simulated actuation signal.

SR 3.6.6.7 Verify each containment cooling train starts 18 months automatically and minimum cooling water flow rate is established on an actual or simulated actuation signal.

SR 3.6.6.8 Verify each spray nozzle is unobstructed.

Following maintenance which could result in nozzle blockage Wolf Creek - Unit 1 3.6-18 Amendment No. 123,!6-7,

Attachment IV to WO 12-0035 Page 1 of 3 ATTACHMENT IV PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (For Information Only)

Attachment IV Page 2 of 3 pAqp:.

'to WO 12-0035 Containment Spray and Cooling Systems Cb0-vwta-6v%

oý 0F'rERA.S1%-%'TY 4

VUVbDjC B 3.6.6 SURVEILLANCE SR 3.6.6.8 REQUIREMENTS (continued)

With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment durinn an accident is not de raded. Due to the passive design of the nozzle, af;V_

~ritrvaIs is considered adequate to detect obstruction of the nozzles.=

REFERENCES

1.

10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41. GDC 42, and GDC 43, and GDC 50.

2.

10 CFR 50, Appendix K.

3.

USAR, Section 6.2.1.

4.

USAR, Section 6.2.2.

5.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

6.

Performance Improvement Request 2002-0945.

Wolf Creek - Unit 1 B 3.6.6-9 Revision 32

Attachment IV to WO 12-0035 Page 3 of 3 INSERT B 3.6.6-9 Confirmation that the spray nozzles are unobstructed may be obtained by utilizing foreign material exclusion (FME) controls during maintenance, a visual inspection of the affected portions of the system, or by an air or smoke flow test following maintenance involving opening portions of the system downstream of the containment isolation valves or draining of the filled portions of the system inside containment. Maintenance that could result in nozzle blockage is generally a result of a loss of foreign material control or a flow of borated water through a nozzle. Should either of these events occur, a supervisory evaluation will be required to determine whether nozzle blockage is a possible result of the event. For the loss of FME event, an inspection or flush of the affected portions of the system should be adequate to confirm that the spray nozzles are unobstructed since water flow would be required to transport any debris to the spray nozzles. An air flow or smoke test may not be appropriate for a loss of FME event but may be appropriate for the case where borated water inadvertently flows through the nozzles.