ML17278A579

Application for Amend to License NPF-21,modifying Tech Spec Table 3.6.3-1, Primary Containment Isolation Valves & Changing Valve FPC-V-149 from Manual to Automatic.Fee Paid

ML17278A579
Person / Time
Site:	Columbia
Issue date:	01/17/1986
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
Shared Package
ML17278A581	List: ML17278A579 ML17278A582
References
GO2-86-083, GO2-86-83, TAC-60548, TAC-60953, NUDOCS 8601270233
Download: ML17278A579 (15)

Text

REQULATP Y INFORMATION DISTRIBUTION 'STEN (BIDS)

ACCESSION NBR: 8601270233 DOC. DATE: 86/01/17 NOTARIZED: YES DOCKET ¹ FACIL: 50-397 WPPSS Nuclear Progecti Unit 2i Washing ton Public Porte 05000397 AUTH. NANE AUTHOR AFFILIATION SORENSENi Q. C. Washington Public Paver Supply System RECIP. NANE RECIPIENT AFFILIATION SUB JECT: Application for amend to License NPF-2ii modi f ging Tech Sp ec Table 3. 6. 3-1> "Primary Containment Isolat ion Valves" changing valve FPC-V-149 fram manual to automatic. Fee paid.

DISTRIBUTION CODE; A001D COPIES RECEIVED: LTR ENCL SIZE:

TITLE: OR Submittal: Qeneral Distribution

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NOTES: 05000397 OL: 12/20/83 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NANE LTTR ENCL ID CODE/NANE'WR LTTR ENCL BWR ADTS 1 0 PD3 PD 01 5 5 BWR EB 1 1 BWR EICSB 1 BWR FOB 1 1 BRADFUTE> J 1 1 BWR PSB 1 1 BWR RSB 1 1 INTERNAL: ACRS 09 6 6 ADM/LFNB 1 0 ELD/HDS2 1 0 NRR/DHFT/TSCB 1 NRR/ AB NRR/ORAS 1 0 Q FILE 04 1 1 RQN5 1 1 EXTERNAL: 24X 1 1 EQhQ BRUSKE> S 1 1 LPDR 03 1 1 NRC PDR 02 i.

NSIC 05 1 1 TOTAL NUNBER OF COPIES REQUIRED: LTTR 30 ENCL 26

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Washington Public Power Supply System 3000 George Washington Way P.O. Box 968 Richland, Washington 99352-0968 (509)372-5000 January 17, 1986 G02-86-083 Docket No. 50-397 Director of Nuclear Reactor Regulation Attention: Ms. E. G. Adensam, Project'irector 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 SPECIFICATIONS (TABLE 3.6.3-1}

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2. 101, the Supply System hereby requests an amendment to the WNP-2 Technical Specifications. Specifically, the following changes are being requested:

1) Modify Table-3.6.3-1, Primary Containment Isolation Valves 2} Change Valve FPC-V-149 from manual to automatic.

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'3 3 3 [3 3/4 6 22 tl 6 32 3 4 This change is being requested in order to incorporate corrections/

additions to excess flow check valves, TIP valves, and equipment qualifi-cation limits, as well as to re-identify certain valves to reflect current Supply System practices.

A recent review of this section led us to conclude that a number of valves in Table 3.6.3-1 are inappropriately assigned limits for valve stroke time. The only times given in Table 3.6.3-1 which are required specifically by the Chapter .15 analyses are the MSIV closure times of 5 seconds. The vent and purge system isolation valves are required to stroke closed in 4 seconds in order to comply with Branch Technical Position (BTP} CSB 6-4, Containment Purging During Normal Plant Operations.

The other stroke times given in this table are, in general, based on design minimums.

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E. G. Adensam Page Two January 17, 1986 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATIONS (TABLE 3.6. 3-1) it It is the Supply System's position that is not necessary to apply standard commercial valve stroke times as limits for valve operability, which is covered by ASME,Section XI. Where valid stroke time limits'are necessary to ensure the adequecy of the primary containment isolation system, these limits need to be included in Table 3.6.3-1. The remainder, those which do not represent a limit required for containment isolation, should be deleted from this table.

The limits for any valve in section d, Other Containment Isolation Valves, have been deleted from the table. These valves are either manually actuated only or are automatically stroked open/closed for reasons other than containment isolation. They are not identified as requiring Primary Containment and Reactor Vessel Isolation System (PCRVIS) signals in FSAR Section-6.2.4, Containment Isolation System, and therefore none of these values represent valid limits for containment isolation.

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 it is merely correcting the items in the table that were previously evaluated in the FSAR.

2} Create the possibility of a new or different kind of accident from any accident previously evaluated because this change does not alter conditions assumed in the FSAR evaluation.

3} Involve a significant reduction in the margin of safety because no limits are being altered that are required'for containment isolation.

Chan'e'No.'

This change is being requested in order to provide a redundant motor-operated isolation valve in the suppression pool cleanup return line.

This automatic valve has been added as a result of a Fuel Pool Cooling (FPC} upgrade that was accomplished in order to meet the GDC, and is being added (modified} in order to 1) allow use of the FPC fi lter-demins for suppression pool cleanup during reactor operations, and 2} maintain level in the suppression pool. Without the ability to utilize this automatic valve, suppression pool level will have to be maintained utilizing an RHR pump, thereby unnecessarily challenging an ECCS function.

The Supply System expects to be in a position to utilize this valve in late February or early March. In order to avoid any unnecessary challenges to plant safety systems, we therefore request an expedited review cycle for this amendment. We stand ready to assist the Staff in any way we can.

~y E. G. Adensam Page Three January 17, 1986 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATIONS (TABLE 3.6.3-1)

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 this change contributes to upgrade of suppression pool cleanup portion of FPC system, and adds a second valve in series for containment isolation.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated because this change uses pre-viously approved methods and does not introduce a new accident mode.

3) Involve a significant reduction in the margin of safety because the system upgrade should actually lessen the chance of an accident or malfunction by providing an automatic, redundant isolation function.

The Supply System has reviewed this change per 10 CFR 50.59 and determined that no unreviewed safety questions will result from this amendment. This change has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.

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. Should you have any questions regarding this matter, please contact Hr. P. L. Powell, Manager, WNP-2 Licensing.

Yery truly yours, G. C. Sorensen, Manager Regulatory Programs HLA/tmh Attachments cc: RC Barr - BPA JO Bradfute - NRC C Eschels - EFSEC JB Hartin - NRC RV E Revell - BPA NS Reynolds - BLCP&R AD Toth - NRC Site

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OPERATING LICENSE NPF-21, REqUEST FOR AMENDMENT TO TECHNICAL SPECIFICATIONS STATE OF WASHINGTON )

) (TABLE 3.6.3-1)

County of Benton )

I, G. C. SORENSEN, being duly sworn, subscribe to and say that I am the Manager, Regulatory Programs for the WASHINGTON PUBI IC 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.

OATE r 7 ~W<~yc, 1986 or nsen, anager 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 acknowledge that he signed the same as his free act and deed for the uses hnd purposes therein mentioned.

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GIVEN under my hand and seal this day of , 1986.

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ATTACHMENT Move RCIC-V-64 from section a. Automatic Isolation Valves to section c. Manual Containment Isolation Valves of Technical Specification Table 3.6.3-1 (pgs. 6-24 and 6-27).

2. Correct the EPN's for PI-EFC-X29b/d, X29e/f, X30d/f, X42e/f and X69d/f to the MEL listings of PI-EFC-X29d, X29f, X30a, X42f and X69f (pg. 6-24).

3. Under section b. Excess Flow Check Valves, move PI-EFC-X66, X67, X82b, X84a and X119 from the listing of Reactor Pressure Vessel and PI-EFC-X86A, X86B, X87A and X87B from the listing Other to Containment Atmosphere (pgs. 6-24, 6-25 and 6-26).

4. Add PI-EFC-X8 to the list of Excess Flow Check Valves associated with the Reactor Pressure Vessel. This valve was inadvertently omitted from the Technical Specification table; however, it is included in Surveillance Procedure 7.4.6.3.4. 1 and, therefore, this change does not constitute a safety concern (pg. 6-25).

5. Add CAS-V-730 to section c. Manual Containment Isolation Valves and delete the listing of Containment Air Supply, CAS-V-453, from section d. Other Containment Isolation Valves. CAS-V-730 was added to the system via a PED and replaces CAS-V-453 as the outboard CIV for penetration X-82e (pgs. 6-26 and 6-31).

6. Add notes (g) and (b} after RCIC-Y-742. This valve is a sample isolation valve on the head spray line and will be hydro tested with RCIC-V-13 and 66 (pg. 6-27).

7. Move RHR-V-124A, 124B, 125A and 125B from section d. (pg. 6-30) to section c. (pg. 6-27). These valves are now Manual Containment Isolation Valves.

8. Correct the typo on page 6-29 by changing RCIC-B-68 to read RCIC-V-68.

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9. Delete RHR-RV;.55A, B from page 6-29 and RHR-RV-95A, B from page 6-30. These, valves have been removed from the system.

10. Add a new listing to section d. for Radiation Monitoring. PI-EFCX-72f and 73e are Coiitainment Isol'ation Valves and were previously omitted from this table (pg. 6-32).

Correct the referenced Technical Specification in note (g) (pg. 6-32) from 4.4.3.2d to 4.4.3.2.2.

NOTE: The current revision of Surveillance Procedure 7.4.6. 1.2.4 for Local Leak Testing takes into account the changes made in steps 5, 6, and 10; therefore, these changes do not constitute a safety concern.

12. Correct TIP system containment isolation valve (CIV) EPN's (pg. 6-22 and 6-32) per DCP 84-1672-OA. Delete TIP-V-11 from the Table (pg. 6-22); this valve is not a CIV.

TIP-V-6, the N purge supply check valve, is the CIV. Add note e) to ind)cate exemption from Type C leak rate testing for the TIP shear valves as previously approved in FSAR Table 6.2-16.

13. Add note j) to Table 3.6.3-1 for RCIC-V-8, RCIC-V-63, RWCU-V-1, and RWCU-V-4 (see pgs. 6-23, 6-24, and 6-32).

14. Delete any maximum isolation times',ilisted for valves in section d.

Other Containment Isolation Valves of Table 3.6.3-1 in Technical Specification (replace with "NA"). These valves do not..receive automatic isolation signals and the given stroke times do not represent stroke times required to meet containment isolation criteria as described in section 6.2.4 of the WNP-2 FSAR.

Individual justifications are as follows:

HSLC-V-3A, B, C, D Hain steam leakage control isolation valves, these valves are normally closed. System is initiated after a LOCA, The valves auto-isolate on high leakage conditions.

RFW-V-.65A, B Feedwater isolation valves, auto-isolation is not desirable since the feedwater system is potentially a significant source of makeup. Feedwater check valves on either side of the containment provide immediate leak isolation, if required.

RWCU-V-40 RWCU vessel return isolation valve, can be manually closed upon indication that the RWCU pumps have tripped. The feedwater check valves provide immediate isolation.

HPCS-V-4, .15 These valves are the ECCS and drywell spray suction LPCS-V-1, 5 and discharge isolation valves. ECCS operation is RHR-V-16A, B essential during a LOCA; therefore there are no RHR-V-17A, B automatic isolation signals.

RHR-V-42A, B, C RHR-V-4A, B, C HPCS-V-12 These valves are the RCIC and ECCS minimum flow LPCS-FCV valves, they auto open on pump running and low flow.

RHR-FCV-64A, B, C They are shut at all other times.

RCIC-V-19 RCIC-V-68 The RCIC steam exhaust valve, normally open at all times. Should a leak occur, it would be detected and alarmed by the RCIC high temperature leak detection c11 cul t.

RCIC-V-69 The RCIC vacuum pump discharge valve, normally open at all times. Can be remotely closed upon indication that vacuum can no longer be maintained in the baro-metric condenser.

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RCIC-V-13 The RCIC injection valve, only open during system operation. Injection line check valves on either side of containment provide immediate isolation, if required. Auto closes when the turbine throttle valve is closed following a turbine trip.

RCIC-V-31 The RCIC suppression pool suction valve, open only during system operation. Can be closed remotely by the operator on indication that the system is no longer operating.

RHR-V-73A, B RHR heat exchanger vent valves, normally closed.

Only opened for system vent and fill.

RHR-V-134A, B CAC to RHR drain valves, normally closed. Only opened during CAC operation.

CAC-V-2, 15, 11, 6, 4 CAC isolation valves, normally closed. System is CAC-FCV-1A, B, 2A, B CAC-V-8, 13, 17 only placed in operation post-LOCA.

if hydrogen is detected CAC-FCV-3A, B, '4A, B RRC-V-16A, B RRC seal injection isolation valves. Can be remotely tripped upon indication that the CRD or RRC pumps have tripped. The isolation check valves provide immediate isolation.

CIA-Y-20 Non ADS SRV and inboard MSIV 'supply isolation valve.

Can. be remote manually closed on indication of low supply pressure. The isolation check valve provides immediate isolation.

CIA-Y-30A, B ADS SRV supply isolation valves. Can be remote manually closed on indication of low supply pressure.

The isolation check valves provide immediate isolation.

CSP-Y-5, 6, 9 The 4 second closing time limit results from a require-ment given in Branch Technical Position CSB 6-4, Containment Purging During Normal Plant Operations,

.that purge system isolation valve closure times, including instrumentation delays, should not exceed five seconds. However, these valves are butterfly vacuum breakers, not purge system isolation valves.

They only open when a vacuum exists in primary containment. They are normally closed during purging operations.

15. Add FPC-V-149 to Table 3.6.3-1 of Technical Specification (pg. 6-22) per DCP 85-008-OA and 85-008-1C.

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