ML17278A570

Application for Amend to License NPF-21,revising Tech Spec Surveillance Requirement 4.6.1.2.d & Authorizing Exemption from 10CFR50,App J,Section Iii.D Re Type B Test of Drywell Head O-rings Until Spring 1986 Refueling Outage.Fee Paid

ML17278A570
Person / Time
Site:	Columbia
Issue date:	01/17/1986
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML17278A571	List: ML17278A570 ML17278A572
References
GO2-86-082, TAC-60546, NUDOCS 8601270010
Download: ML17278A570 (10)

Text

REGULATORY ORNATION DISTRIBUTION SY N (RIDS>

ACCESSION NBR: 8601270010 DOC. DATE: 86/0 1 /17 NOTARIZED: YES DOCKET 0 FAC IL: 50-397 WPPSS Nuclear Pro Ject> Unit 2i Washington Public Potue 05000397 AUTH. NANE AUTHOR AFFILIATION SORENSENs G. C. Washington Public Power Supply System REC IP. MANE REClP IEN1 AFFILIATION ADENSAN> E. G. BWR Pro Ject Directorate 3 SUB JE'CT: Application for amend to License NPF-21> revising Tech Spec SurveillanceRequirement 4. h. 1. 2. d 5 authorizing exemption from 10CFR50i App Ji Section III. D re Tgpe B test of drgwell head 0-rings until Spring 198b refueling outage. Fee paid.

DISTRIBUTION CODE: A017D COPIES RECEIVED: LTR ENCL SIZE:

TITLE: OR Submittal: Append J Containment Leak Rate Tes ing NOTES O5OO0397 OL: 12/20/83 REC IP IENT COPIES REC IP IENT COPIES ID CODE/MANE LTTR ENCL ID CODE/MANE LTTR ENCL BWR PD3 PD 01 5 5 BRADFUTEi J 1 1 INTERNAL: ACRS 07 10 10 ADN/LFNB 1 0 ELD/HDS2 08 1 NRR BWR *DTS 1 1 NRR PWR-A ADTS 1 -B ADTS 1 1 NRR/DSRO DIR 1 1 REG FIL 04 1 1 RGN5 1 1 EXTERNAL: 24X 1 1 LPDR 03 NRC PDR 02 1 1 NSIC 05 TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 27

h Eg g W~

F~ 1 M

Washington Public Power Supply System 3000 George Washington Way P.O. Box 968 Richland, Washington 99352-0968 (509)372-5000 January 17, 1986 G02-86-082 Docket No. 50-397 Director of Nuclear Reactor Regulation Attention: Ms. E. G. Adensam, Project Director BWR Project Directorate No. 3 Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

NUCLEAR PLANT NO. 2 OPERATING LICENSE NPF-21, REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 4.6.1;2.d, AND EXEMPTION TO APPENDIX J TO 10CFR50 SECTION III.D REGARDING TYPE B TEST OF DRYWELL HEAD "0" RINGS The subject surveillance requirements and Appendix J section specify that type B and C leak rate tests are to be conducted at intervals no greater than 24 months. The WNP-2 drywell head "0" ring type B test was last completed March 19, 1984, making the next test due no later than March 19, 1986. This test requires plant shutdown and shield plug removal to allow access. In consideration of the WNP-2 refueling outage scheduled for spring 1986, the Supply System proposes that a one-time-only technical specification amendment and Appendix J exemption be authorized to allow this test to be accomplished during the forthcoming refueling outage.

As indicated in previous Appendix J exemption requests (Tennessee Valley Authority Browns Ferry Unit 2 and Carolina Power & Light Brunswick Unit 1 requests posted in the Federal Register Volume 49, No. 160, 8/16/84 and Volume 49, No. 242, 12/14/84, respectively), relaxation to the 24 month limit to permit test conduct during refueling outages has been previously granted. The Supply System considers a plant shutdown exclusively for this test with a refueling outage scheduled within weeks of the two year date to be unnecessary.

B~o'>><<to Bsoss7 ADOCg 050<<g9y[

PDR I

~ ',I

~

>r

E. G. Adensam Page Two January 17, 1986 AMENDMENT TO TECH. SPEC. SURV. REQUIREMENT 4.6. 1.2.d AND EXEMPTION TO APPENDIX J TO 10CFR50 SECTION III.D TYPE B TEST OF DRYWELL HEAD "0" RINGS Accordingly, per 10 CFR 50.90 and 2.101, the Supply System requests the subject technical specification surveillance requirement be amended as attached and a one-time-only exemption per 10 CFR 50.12(a) to Appendix J be granted to defer the type B leak rate test on the drywell head "0" rings from March 19, 1986 until the spring 1986 refueling outage. The spring 1986 refueling outage is presently scheduled to begin April 15, 1986.

However, as previously related to the staff, WNP-2 provides power to the Bonneville Power Administration (BPA) grid which is seasonally affected by hydroelectric capacity. As a result, depending on BPA forecasts for the spring runoff, the Supply System may be directed to stay on-line beyond the scheduled date or commence the outage earlier. It is not anticipated that the spring outage, if deferred, will be delayed beyond May -15, 1986.

With regard to the exemption requested, the Supply System considers that it does not represent an undue risk or threat to life or property in that the Appendix J test interval was based on two years of expected exposure of components to service conditions. During the period since March 1984, the time that the drywell head "0" rings have not been exposed to an operating environment (due to outages and the power ascension test program completion} has been approximately 6 months. Hence, potential degradation anticipated over the two year period would be reduced due to less exposure to operating conditions. Therefore, a test concurrent with the spring 1986 refueling outage satisfies the two year basis of Appendix J and provides the ability to test during refueling outages. The refueling outage delay, if any, dependent on spring runoff will be less than 2 months and is still in keeping with the two year intent.

The Supply System considers this exemption request to be in the public interest in that it avoids an unnecessary plant outage and subsequent loss of power generation. In addition, the exemption is desirable in order to maintain personnel exposures as low as reasonably achievable. It is evident that the exemption would achieve the purpose of the rule while compliance without an exemption would be contrary to the public interest as it would result in loss of power generation during a period of high demand (prior to the spring runoff) and a loss of resources and increased personnel exposure which could be better focused on other plant support tasks. As such, it does not endanger public life or property or the common defense and security and is otherwise in the public interest.

Based on the above and the exemption requests posted in the Federal Register (regarding TVA and CPSL}, the Supply System has determined that the exemption request is authorized by law.

~ $ s

~,I 7

E. G. Adensam Page Three 1

January 17, 1986 AMENDMENT TO TECH. SPEC. SURV. RE(UIREMENT 4.6. 1.2.d AND EXEMPTION TO APPENDIX J TO 10CFR50 SECTION III.D - TYPE B TEST OF DRYWELL HEAD "0" RINGS With regard to the requested technical specification amendment, the Supply System has evaluated this request per 10 CFR 50.59 and 50.92 and has determined that no unreviewed safety questions or significant hazards will result. Further, the proposed change will not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated because the total operating exposure of the drywell head "0" rings will be within the two year bases intended by Appendix J. Hence, the change does not represent an increase of any magnitude in the probability or consequences of a previously evaluated, accident.

2) Create the possibility of a new or different kind of accident than previously evaluated because no new designs or plant operating modes are affected by this amendment.

3) Involve a significant reduction in a margin of safety because, as discussed in 1} above, the amendment will still maintain the drywell head "0" rings within the two year bases intended by Appendix J. No margin of safety is impacted; rather, this change allows operation to continue within the original safety margins realized by Appendix J.

In guidance provided by the Staff'Federal Register Vol. 48, No. 67, April 6, 1983}, examples of amendments that are not likely to involve a significant hazards consideration are listed. The request involved in this case does not match any of those examples. However, as noted above, the results of the change are clearly within all acceptable criteria.

This technical specification change and exemption request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.

In accordance"with 10 CFR 170.21, an application fee of One hundred fifty dollars ($ 150.00} accompanies this request. In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter. Should you require further information or assistance to aid in evaluating this request, please contact Mr. P. L. Powell, Manager, WNP-2 Licensing.

t Very truly yours, G. C. S rensen, Manager Regulatory Programs PLP/tmh Attachments cc: RC Barr - BPA E Revell - BPA JO Bradfute - NRC NS Reynolds - BLCPSR C Eschels - EFSEC AD Toth - NRC Site JB Martin - NRC RV

~ ~

OP TING LICENSE NPF-,21, REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 4.6.1.2.d, AND EXEMPTION TO APPENDIX J TO 10CFR50 SECTION III.D REGARDING TYPE B TEST OF DRYWELL HEAD "0" RINGS STATE OF WASHINGTON )

Subject:

)

County of Benton )

I, G. C. SORENSEN, being duly sworn, subscribe to and say that I am the Manager, Regulatory Programs for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that I have full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information and belief the statements made in it are true.

DATE ~ 0+@ , 1986 orensen, ana ger Regulatory Programs On this day personally appeared before me G. C. Sorensen to me known to be the individual who executed the foregoing instrument and acknowl'edge that he signed the same as his free act and deed for, the uses and purposes 'therein mentioned.

seal this / day of , 1986.

GIVEN under my hand and oar u conan or e State of W shin t n Residing at ,/

~ ~ ~ ~

f "l

S