ML17277B723

Application for Amend to License NPF-21,revising Tech Specs Re Surveillance Requirement 4.6.1.1 to Allow Certain Containment Isolation Valves to Be Excluded While Plant at Power,To Avoid Unnecessary Personnel Hazards.Fee Paid

ML17277B723
Person / Time
Site:	Columbia
Issue date:	04/25/1985
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML17277B724	List: ML17277B723 ML17277B725
References
GO2-85-216, TAC-57546, NUDOCS 8505010150
Download: ML17277B723 (7)

Text

REGULAP'NPORNAT ION IBUTII+S'EN (RIBS)

DISTR ACCESSION NBR;8505010150 DOC DATE: 85/04/25 NOTARIZED YES DOCKET e FACIL!$0'-397 HPPSS Nuclear ProJecti Unit 2'i Washington Public= Powe. 05000397 A'UTH', NAME AUTHOR AFF ILI'ATION SORENSENiGGG; klashi*ngton- Public Power Supply System RECIP ~ NAMEi RECIPIENT. AFFILIATION SCHNENCERe" ~ L1censsng Branch ?

SUBJECT:

Applicat)on for amend to License. NPF 21rrevising Tech Surveillance Requirement 4 '-, 1, 1.to allow certain Specs'e containment isolation valves to bo.. excluded while plant-at powerito avoid unnecessary personnel hazards,Fee paid,'ISTRIBUTION CODE ~ A001D COPIES RECEIVED:LTR ENCL~ SIZE's T'ITLE".= OR Submittal: General Distr ibution NOTES'L 05000397 i 12/20/83 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAMEi LTTR ENCL ID'CODE/NAME LTTR ENCL" NRR'LB2 BC 01 7 7 INTERNAL ACRS 09- 6 6 ADM/LFMB 0 ELD/HDS2 1 -0 NRR/DE/MTEB 1 NRR/DL 1 1 NRR/DL/ORAB 0 DIR'RR/DL/TSRG.

1 1 NR B 1 NRR/DSI/RAB 1 1 04 1 RGN5 1 1 EXTERNAL; EGEG BRUSKEgS 1 1 LPDR 03~

NRCI PDRI 02 1 1 NSIC 05 TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 24

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Washington Public Power Supply System P.O. Box 968 3000 George Washington Way Richland, Washington 99352 (509) 372-5000 Apri 1 25, 1985 G02-85-216 Docket No. 50-397 Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Schwencer:

Subject:

NUCLEAR PLANT NO. 2 OPERATING LICENSE NPF-21, REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 4.6.1.1 (PRIMARY CONTAINMENT INTEGRITY)

In accordance with the Code of Federal Regulations (CFR), Title 10, Parts 50.90 and 2.101, the Supply System hereby requests an amendment to the Technical Specifications. Specifically, the Supply System is requesting a change to Surveillance Requirement 4.6. 1.1 (pg. 3/4 6-1 attached) which will allow certain containment isolation valves to be excluded from routine surveillance requirements while the plant is at power in order to avoid un-necessary personnel hazards from both a safety and ALARA standpoint.

During plant operations there are, and will be, areas within the plant that operate at high radiation levels and/or very high temperatures that make personnel access extremely hazardous. Some of the containment isolation valves are either located in these areas or require passing through these areas in order to perform the 31 day surveillance requirements. Entry into or through these areas creates unnecessary personnel safety, hazards and/or is inconsistent with established ALARA practices. The Supply System is therefore seeking an amendment to allow us to institute certain administrative controls that are meant to ensure containment integrity, which would justify a waiver of the 31 day surveillance requirement except during periods of Cold Shutdown (CSD).

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A. Schwencer Page Two April 25, 1985 REQUEST FOR AMENDMENT TO TECH. SPEC. SURVEILLANCE REQUIREMENT 4.6.1. 1 At present, the areas where these valves are located are locked, posted as high radiation areas, and require a Radiation Work Permit (RWP) and authoriza-tion from Health Physics to access the'reas on an "as needed" basis. In addition, after the valves are verified as being in the proper position, they are locked, sealed, or otherwise secured in the closed position. These administrative controls ensure containment integrity'hile at the same time allow the plant personnel to avoid unnecessary radiat'ion exposure and/or personal injury due to high temperatures. This change is an extension of current Technical Specification philosophy pertaining to valves inside the primary containment.

The Supply System has reviewed this change per 10 CFR 50.59 and determined that no unreviewed safety questions will result from this amendment.

The Supply System has reviewed this change per 10 CFR 50.92 and determined that it does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated because there is no change to the valves or their positions. This change reflects only access restrictions which prevent position verification while at power; or

2) Create the possibility of a new or different kind of accident than previously evaluated because this is an administrative change only and does not impact system operation; or

3) Involve a significant reduc'tion in a margin of safety because it does not change the leakage paths or rates assumed in the WNP-2 Final Safety Analysis Report (FSAR).

The Supply System has evaluated this request in accordance with the criteria contained in 10 CFR 170.21 and has included a warrant for One hundred fifty dollars ($ 150.00) as initial payment for this application for amendment under Facility Category A (Power Reactors).

In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.

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A. Schwencer Page Three April 25, 1985 REQUEST FOR AMENDMENT TO TECH. SPEC. SURVEILLANCE REQUIREMENT 4.6. 1.1 This Technical Specification change has been reviewed and approved by the WNP-2 Plant Operations Committee (POC) and the Supply System Corporate Nuclear Safety Review Board (CNSRB).

Should you have any questions, please contact Mr. P. L. Powell, Manager, WNP-2 Licensing.

Ver truly yours, G. C. orensen, Manager Regulatory Programs HLA/tmh Attachments cc: JO Bradfute NRC WS Chin - BPA C Eschels - EFSEC JB -

Martin NRC RV E Revell - BPA AD Toth - NRC Site