GO2-97-019, Comments on Final Draft SE of Proposed Conversion to Improved TS
| ML17292A675 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/31/1997 |
| From: | Webring R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GO2-97-019, GO2-97-19, NUDOCS 9702100280 | |
| Download: ML17292A675 (10) | |
Text
C CATEGORY 1 REGULAT INFORMATION DISTRIBUTIOh,.i STEM (RIDS)
ACCESSION NBR:9702100280 DOC.DATE: 97/Ol/31 NOTARIZED:
NO FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe AUTH.NAME AUTHOR AFFILIATION WEBRING,R.L.
Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Comments on final draft SE of proposed conversion to improved TS.
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968
~ Richland, Washington 99352-0968 January 31, 1997 G02-97-019 Docket'No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen:
'ubject:
~.,WNP-2, OPERATING LICENSE NPF-21 COMMENTS ON FINALDRAFT SAFETY EVALUATION
References:
1)
Letter dated January 9, 1997, TG Colburn (NRC) to JV Parrish (SS)
"Final Draft Safety Evaluation of Proposed Improved Technical Specifications, Washington Public Power Supply System WNP-2" 2)
Letter, GO2-97-006, dated January 14, 1997, PR Bemis (SS) to NRC, "Request for Amendment to the Technical Specifications Additional Information" In Reference 1, the staff provided the Supply System an opportunity to review the final draft safety evaluation (SE) of the proposed conversion to Improved Technical Specifications (ITS).
The comments are listed, by page number, as an attachment to this letter.
These comments are for those areas. of the SE where clarification may be appropriate or where typographical errors could lead to confusion, In Reference 2, the Supply System provided the staff a final copy of the proposed ITS.
As discussed with TG Colburn, an additional change other than those noted in Reference 2 was made.
In the preparation of the Figure 3.4.11-3 on page 3.4-30 for transfer to Word Perfect 5.1 format, a typographical error was corrected.
A coordinate on the figure had been incorrectly labeled (148', 312 psig).
This was changed to indicate the correct temperature
)
of 140' rather than 148'.
The correction of this error brings the figure into agreement with the current Technical Specification Figure 3.4.6.1B.
I 9702i00280 970i3i PDR ADOCKI 05000397 i'
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Page 2 COMMENTS ON FINALDRAFT SAFETY EVALUATION Should you have any questions or require additional information pertaining to this letter, please contact either me or Ms. L.C. Fernandez at (509) 377-4147.
Respectfully, R.L. Webring Vice President, Operation Support/PIO Mail Drop PE08
Attachment:
Technical Comments CC:
LJ Callan - NRC RIV JE Dyer - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office TG Colburn - NRR NRC Sr. Resident Inspector - 927N DL Williams BPA/399 NS Reynolds - Winston & Strawn
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e COMMENTS ON FINAL DRAFT SAFETY EVALUATION Attachment Page 1 of 2 TECHNICAL COMMENTS PAGE NUMBER 13 14 15 18 19 PARAGRAPH NUMBER ISSUE 12th definition should be ISOLATION SYSTEM Reformatted definitions contains g 1.18. It should be g 1.16. Definition 1.18 is not in ITS 1.4 Definition 1.18 should be 1.16 The end of the ara ra h should reference LCO 3.4.11 Nominal setpoints are not "specified in the LCS."
As part of implementation the setpoints will be relocated to FSAR or LCS 20 34 35 74 75 77 95 States that requirements will be moved to QA Program.
Submittal says FSAR or LCS The 3rd sentence, "CTS 3.1.3.7, Action A.3 rovides...," is incorrect and should be deleted.
The last sentence states that adding the words "following CORE ALTERATIONS" is acceptable.
These words are not in SR 3.1.3.5.
DOC says that "work" encompasses core alterations.
List of channel calibrations extended to 24 months does not include RWCU blow down flow.
See Volume 5, Section 3.3.6.1, page 11 of 12, DOC LE.1 Replace the last sentence with, "regardless of other channel status."
This paragraph states that the licensee verifies the operability of instrumentation during in-house calibration surveillances.
This is correct.
Zt also states that setpoint calculation assumptions continues to be met during routine surveillances.
The Supply System does not compare the results of routine surveillances to the setpoint calculationsi but does verif o erabilit Discussion of CTS 3.3.4.1 should refer to ITS SR 3.3.4.2.4 not 3.3.4.1.4.
123 125 129 3.3.1.2 is SRMs not control rod block.
Change from "containment" system to "instrumentation" system Licensee "plans" to adopt staff allowance, rather than "ado ted".
162 206 210 li2 The chan e described in this ara ra h was withdrawn.
The discussion is not technically accurate for WNP-2 analysis.
This paragraph should be labeled "3/4.7.3" and the paragraph should be moved to follow 3.7.7 discussion.
The next paragraph is applicable to the section labeled "3.7.3" that starts on page 208.
This is confusing because the second paragraph does not relate to RCIC and because the first paragraph is not applicable to any STS in section 3.7.
Ir
COMMENTS ON FINAL DRAFT SAFETY EVALUATION Attachment Page 2 of 2 TECHNICAL COMMENTS PAGE NUMBER 212 213 220 PARAGRAPH NUMBER ISSUE Change SR 3.7.1.2 to 3.7.2.2 Applicable to CTS 4.7.2.e.2, not 4.7.2.3.2 The WNP-2 submittal did NOT evaluate the relocation of CTS 3/4.7.4, Snubbers against the "Final Policy Statement" or 10 CFR 50.36.
221
- 243, The justification for this relocation is discussed as a less restrictive change in Volume 6, section 3/4.7.4.
The Supply System submittals for the conversion do not include an evaluation against the criteria discussed in this paragraph.
The paragraph should be revised to make it clear that the evaluation against 50.36 was performed by the staff rather than the licensee.
The 3rd sentence should be changed to "The 250 volt battery and charger provide power through a solid state invertor to various reactor core isolation cooling (RCZC), residual heat removal (RHR) and reactor water cleanup (RWCU) valves and to non-TS equipment such as plant controls, instrumentation, computer and communication equipment."
The 5th sentence should be changed near the end to "this change is acceptable because the specification for RCIC (ITS 3.5.3) and
248 277 These same corrections should be made in the 2nd ara ra h on a e 248.
The conclusion states that none of the specifications met the four criteria.
CTS 3.9.4 met criterion 2.
(see SER page 276)
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