ML25043A149
| ML25043A149 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/26/2025 |
| From: | Samson Lee NRC/NRR/DORL/LPL4 |
| To: | Reasoner C Wolf Creek |
| Lee S, 301-415-3168 | |
| References | |
| EPID L 2024-LLA-0109 TSTF-569 | |
| Download: ML25043A149 (1) | |
Text
February 26, 2025 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. 243 RE: REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TSTF-569, REVISION 2, REVISE RESPONSE TIME TESTING DEFINITION (EPID L-2024-LLA-0109)
Dear Cleveland Reasoner:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 243 to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated August 14, 2024.
The amendment revises the TS definitions for engineered safety feature response time and reactor trip system response time to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-569, Revision 2, Revise Response Time Testing Definition.
A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Samson S. Lee, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482
Enclosures:
- 1. Amendment No. 243 to NPF-42
- 2. Safety Evaluation cc: Listserv
WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION, UNIT 1 DOCKET NO. 50-482 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 243 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 14, 2024, 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.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-42 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 243, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.
229, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
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 Tony T. Nakanishi, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License and the Technical Specifications Date of Issuance: February 26, 2025 Tony T.
Nakanishi Digitally signed by Tony T. Nakanishi Date: 2025.02.26 07:01:33 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 243 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK GENERATING STATION, UNIT 1 DOCKET NO. 50-482 Replace the following pages of Renewed Facility Operating License No. NPF-42 and the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Renewed Facility Operating License REMOVE INSERT 4
4 Technical Specifications REMOVE INSERT 1.1-3 1.1-3 1.1-5 1.1-5
4 (5)
The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6)
The Operating Corporation, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level The Operating Corporation is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100%
power) in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 243, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 229, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Antitrust Conditions Evergy Kansas South, Inc. and Evergy Metro, Inc. shall comply with the antitrust conditions delineated in Appendix C to this license.
(4)
Environmental Qualification (Section 3.11, SSER #4, Section 3.11, SSER #5)*
Deleted per Amendment No. 141.
- The parenthetical notation following the title of many license conditions denotes the section of the supporting Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
Renewed License No. NPF-42 Amendment No. 243
Definitions 1.1 Wolf Creek - Unit 1 1.1-3 Amendment No. 123, 131, 170, 221, 236 1.1 Definitions (continued)
DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-87, Kr-88, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using the effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.
ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its ESF actuation TIME setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.
LEAKAGE LEAKAGE shall be:
a.
Identified LEAKAGE 1.
LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff); that is captured and conducted to collection systems or a sump or collecting tank; 2.
LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or 3.
Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);
(continued)
, 243
Definitions 1.1 Wolf Creek - Unit 1 1.1-5 Amendment No. 123, 170, 180, 221 1.1 Definitions (continued)
PRESSURE AND The PTLR is the unit specific document that provides the TEMPERATURE LIMITS reactor vessel pressure and temperature limits, including REPORT (PTLR) heatup and cooldown rates and the power operated relief valve lift settings and the Low Temperature Overpressure Protection (LTOP) System arming temperature, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6.
QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore RATIO (QPTR) detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.
RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 3565 MWt.
REACTOR TRIP The RTS RESPONSE TIME shall be that time interval from SYSTEM (RTS) RESPONSE when the monitored parameter exceeds its RTS trip setpoint TIME at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.
SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:
a.
All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and b.
In MODES 1 and 2, the fuel and moderator temperatures are changed to the hot zero power temperatures.
(continued) 243
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 243 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 application dated August 14, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24227A556), Wolf Creek Nuclear Operating Corporation (the licensee) submitted a license amendment request (LAR) for the Wolf Creek Generating Station, Unit 1 (Wolf Creek). The amendment would revise technical specification (TS) definitions for engineered safety feature (ESF) response time and reactor trip system (RTS) response time that are referenced in surveillance requirements (SRs), hereafter, referred to as response time testing (RTT).
The proposed changes are based on Technical Specifications Task Force (TSTF) traveler TSTF-569, Revision 2, Revise Response Time Testing Definition, dated June 25, 2019 (ML19176A034). The U.S. Nuclear Regulatory Commission (NRC or the Commission) issued a final safety evaluation (SE) approving TSTF-569, Revision 2, on August 14, 2019 (ML19176A191). The description of the generic changes and their justification are contained in these two documents.
2.0 REGULATORY EVALUATION
2.1 Description of Response Time Testing The RTS for Wolf Creek initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and the reactor coolant system (RCS) pressure boundary during anticipated operational occurrences and to assist the engineering safety feature actuation system (ESFAS) in mitigating accidents. The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary and to mitigate accidents.
The RTT verifies that the individual channel or train actuation response times are less than or equal to the maximum values assumed in the accident analyses. The RTT acceptance criteria are under licensee control. Individual component response times are not modeled in the
accident analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor to the point at which the equipment reaches the required functional state (e.g., control and shutdown rods fully inserted in the reactor core).
2.2 Proposed Changes to the Technical Specifications Wolf Creek Limiting Condition for Operation (LCO) 3.3.2, requires the ESFAS instrumentation for each Function in TS Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, to be OPERABLE. To assure the LCO is met, SR 3.3.2.10 requires the licensee to verify that ESF RESPONSE TIMES are within limits. Similarly, Wolf Creek LCO 3.3.1 requires the RTS instrumentation for each Function in TS Table 3.3.1-1, Reactor Trip System Instrumentation, to be OPERABLE, and SR 3.3.1.16 requires the licensee to verify that RTS RESPONSE TIMES are within limits. Section 1.1 of the TS definitions for ESF RESPONSE TIME and RTS RESPONSE TIME, which describes acceptable means to measure each response time, and provide an alternative that may be used [i]n lieu of measurement.
In its application, the licensee stated that it requests adoption of NRC-approved TSTF-569, Revision 2. The only revision of TSTF-569 that is NRC approved is Revision 2. As described in section 1, Summary Description, of Revision 2 of TSTF-569:
The proposed change revises the definitions to eliminate the requirement for prior NRC review and approval of the response time verification of similar components, while retaining the requirement for the verification to be performed using the methodology contained in Attachment 1, titled, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing. The proposed change will permit licensees to verify the response time of similar component types using the methodology contained in Attachment 1, without obtaining prior NRC approval for each component.
Accordingly, as shown in the LAR, the request would add an additional in lieu of measurement alternative to measuring ESF RESPONSE TIME and RTS RESPONSE TIME. The additional alternative for ESF RESPONSE TIME would be [i]n lieu of measurement, response time may be verified for selected components provided... the components and the methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology. Similarly, for RTS RESPONSE TIME, [i]n lieu of measurement, response time may be verified for selected components provided that... the components and the methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.
The application stated that the licensee concluded that the justifications presented in TSTF-569 and the SE prepared by the NRC staff are applicable to Wolf Creek and provide the justification for the amendment request.
2.2.1 Variations The Wolf Creek TS Definition of ESF Response Time contains slightly different wording compared to the improved standard technical specifications (ISTS) of NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Revision 5, Volume 1, Specifications, and Volume 2, Bases, dated September 2021 (ML21259A155 and ML21259A159, respectively).
as described in TSTF-569-A, Revision 2. The Wolf Creek TS states, The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function. The ISTS of NUREG-1431 states, The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function.
2.3 Applicable Regulatory Requirements and Guidance Under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, whenever a holder of a license wishes to amend the license, including TSs in the license, an application for amendment must be filed, fully describing the changes desired. Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Both the common standards for licenses in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public, and that the applicant will comply with the Commission's regulations.
The licensee's request involves adding an option used to satisfy SRs. As described in 10 CFR 50.36(c):
Surveillance requirements are 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.
3.0 TECHNICAL EVALUATION
The NRC staff reviewed the request by comparing the licensees proposal against the changes described in TSTF-569, Revision 2. TSTF-569 is designed to make changes to NUREG-1431, Revision 5.0. The staff compared the TSs assumed in TSTF-569 with the current technical specifications for Wolf Creek. The staff did not identify any material differences in the relevant technical specifications.
In the NRC SE for TSTF-569, the NRC staff concluded that the proposed change to TS section 1.1 would eliminate required direct measurement RTT for selected pressure transmitter/sensor and protection channel components but does not eliminate required surveillance testing for the entirety of an instrument channel or the system as a whole (e.g.,
RTS). Therefore, the NRC staff found that the proposed change is consistent with the surveillance testing requirements of 10 CFR 50.36, Technical specifications.
The NRC staff confirmed that the proposed change in this LAR has no effect on the design, fabrication, use, or methods of testing of the instrumentation and will not affect the ability of the instrumentation to perform the functions assumed in the safety analysis. Therefore, compliance with the General Design Criterion (GDC) 13 and GDC 21 of Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants, or the equivalent plant-specific criteria is not affected.
The NRC staff finds that the methodology contained in TSTF-569, Revision 2, attachment 1, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only), provides a consistent, clear, and concise framework for determining that replacement components will operate at a level equivalent to that of the components being replaced. As such, using that methodology will assure that the necessary quality of the components is maintained and that the LCOs will be met. Accordingly, approving the incorporation of that methodology into the licensing basis, amending the TS to allow usage of the approved methodology, and approving the LAR to use the methodology in TSTF-569, Revision 2, results in TSs that continue to meet the requirements of 10 CFR 50.36(c)(3). These requirements will be continued to be met by performing SR 3.3.1.16 while using the new [i]n lieu of option and will assure that associated aspects of LCO 3.3.1 and 3.3.2 will be met.
3.1 Variations The licensee proposed a variation, described in section 2.2.1 of this SE, from the TS changes described in TSTF-569 and the applicable parts of the NRCs SE. The NRC staff reviewed the variation and determined that it is editorial in nature and continue to meet the intent of TSTF-569. The Wolf Creek TS definition of ESF Response Time including the acronym ESF prior to the term actuation does not affect the applicability of TSTF-569 to the Wolf Creek TS.
Therefore, the proposed variation is acceptable.
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 October 22, 2024. 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 and change SRs.
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, and there has been no public comment on such finding published in the Federal Register on October 29, 2024 (89 FR 85994). 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 Contributor: Tarico Sweat, NRR Date: February 26, 2025
- concurrence via email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA* NRR/DSS/STSB/BC*
NRR/DORL/LPL4/BC*
NAME SLee PBlechman SMehta TNakanishi DATE 2/12/2025 2/18/2025 1/7/2025 2/26/2025 OFFICE NRR/DORL/LPL4/PM*
NAME SLee DATE 2/26/2025