ML17285A240

Application for Amend to License NPF-21,incorporating Clarifications to Tech Spec Sections 3.0 & 4.0, Limiting Conditions for Operation & Surveillance Requirements, Per Generic Ltr 87-09

ML17285A240
Person / Time
Site:	Columbia
Issue date:	02/09/1989
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17285A241	List: ML17285A240 ML17285A242
References
GL-87-09, GL-87-9, GO2-89-016, GO2-89-16, NUDOCS 8902150371
Download: ML17285A240 (7)

Text

gcgPLZ~TED DlGBUTlOA DEMONSTPTI04 SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8902150371 DOC.DATE: 89/02/09 NOTARIZED: NO DOCKET g FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION SORENSEN,G.C. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to License NPF-2l,incorporating clarifications & recommedations per GL 87-09. I DISTRIBUTION CODE: A001D TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution ENCL SIZE- Ado ~

NOTES:

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s4. s WASHINGTON PUBLIC POWER SUPPLY SYSTEM F.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 February 9, 1989 G02-89-016 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 OPERATING LICENSE NPF"21, RE(}UEST FOR AMENDMENT TO TECHNICAL SPECIFICATION SECTIONS 3.0 AND 4.0 "LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS" AS RECOMMENDED BY GENERIC LETTER 87"09 In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, the Supply System hereby submits a request for, amendment to the HNP-2 Technical Specifications. Specifically, the Supply System is requesting that the clarifications and recommendations provided by the Staff in Generic Letter.

87-09 be incorporated (as attached) in the MNP-2 Technical Specifications.

The changes requested are to specifications 3.0.4, 4.0.3 and 4.0.4 and are as recommended by the generic letter,. Briefly:

o The change to 3.0.4 would alleviate unnecessary restrictions on mode changes. This proposal would allow mode changes when in an ACTION state-ment that allows continued operation for, an unlimited period of time.

With the change to Specification 3.0.4, individual exceptions to 3.0.4 where the ACTION statement does not require a shutdown are no longer.

necessary. Exceptions to 3.0.4 in specifications that do require a plant shutdown are retained. Deletions of the appropriate exceptions are pro-vided in the attached marked-up specifications.

S902150371 890209 PDR ADOCK 0500039'7 P PDC

Page Two REQUEST fOR AMENDMENT TO TS SECTIONS 3.0 AND 4.0 o The proposed change to 4.0.3 would eliminate unnecessary shutdowns which are now r equired if a surveillance inter val is inadvertently surpassed.

The change would allow delaying compliance with an ACTION statement for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in order, to allow performance of a missed surveillance.

Therefore, if a missed surveillance can be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, plant shutdown would not be required.

o The proposed change to 4.0.4. is necessary to allow the plant to proceed through or, to required operational modes to comply with ACTION require-ments even though applicable surveillance requirements may not have been performed.

The Staff, in Generic Letter 87-09, concluded that these modifications would result in improved technical specifications and encouraged licensees to proceed with requesting these changes. Requested modifications to the Bases associated with these specifications, as recommended by the Staff, are also enclosed.

The Supply System has evaluated this amendment request per, 10CFR50.59 and 50.92 and determined that it does not r epresent an unreviewed safety question or, a significant hazard because it does not:

I) Involve a significant increase in the probability or. consequences of an accident previously evaluated because:

The change to Specification 3.0.4 will allow mode changes while the plant is in an ACTION statement which does not prohibit power operation. Excep-tion to 3.0.4 has already been taken in many of the individual ACTION statements. Incorporating the proposed change into 3.0.4 will ensure that exceptions will be consistently applied when justified. Deletion of the individual exceptions will have no impact upon the requirements in the Specifications since the exception to 3.0.4 will now be contained within 3.0.4.

The change to Specification 4.0.3 will allow delay in the application of ACTION requirements for. up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when a surveillance has been missed. Because surveillances normally verify system or, component opera-bility, as opposed to discovering inoperability, the allowance of an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to demonstrate operability is not significant. With-out the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, delay it is likely that a missed surveillance would force a plant shutdown. Avoidance of this transient state and associated thermal cycling is beneficial and far. outweighs any incremental uncertainties regarding system operability associated with the addi-tional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in which to perform a missed surveillance.

Page Three REQUEST FOR AMENDMENT TO TS SECTIONS 3.0 AND 4.0 The change to Specification 4.0.4 will not result in a change to the design or. operation of the facility and is administrative in nature. This change will not result in an increase in the probability or, consequences of an accident.

2) Create the possibility of a new or. different kind of accident from any accident previously evaluated because:

The change to 3.0.4 will allow the plant to continue operation in an ACTION statement which already allows continued operation. As such, no new modes of operation are being introduced by this change.

The change to 4.0.3 would allow the plant to continue operation for an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after, discovery of a missed surveillance. Missing a surveillance does not mean that a component or, system is inoperable. In most cases surveillances demonstrate the continued operability of the components and systems. All systems and components currently required to be verified operable by Technical Specification requirements will continue to be maintained operable. This change will not affect the design of the plant and will not allow the plant to be operated outside the currently allowed modes of operation.

The change to 4.0.4 will alleviate a contradiction within the specifica-tions. This change is administrative and does not affect any of the accident analysis.

3) Involve a significant reduction in a margin of safety because:

The change to Specification 3.0.4 will allow mode changes in ACTION state-ment that do not require plant shutdown. Exceptions to 3.0.4 are already contained within many of the applicable ACTION statements. Incorporating the exceptions within 3.0.4 will ensure their. consistent application.

The change to 4.0.3 will allow up to 24 hours to perform a missed surveillance. In most cases this will eliminate the need for a plant shutdown. The overall effect is a net gain in plant safety due to avoidance of unnecessary shutdowns due to missed surveillances.

The change to 4.0.4 is administrative in nature and therefore does not affect any margin of safety.

Page Four, REQUEST fOR AMENDMENT TO TS SECTIONS 3.0 AND 4.0 As discussed above, the Supply System considers that this change does not involve a significant hazards consideration, nor. is there a potential for.

significant change in the types or significant increase in the amount of any effluents that 'may be released offsite, nor does it involve a significant increase in individual or cummulative occupational radiation exposure. Accor,-

dingly, the proposed change meets the eligibility criteria for, categorical exclusion set for th in 10CFR 51.22(c)(9) and therefore, per 10CFR 51.22(b), an environmental assessment of the change is not required.

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).

Very truly yours, G. C. S rensen, Manager, Regulatory Programs PLP/bk Attachments cc: C Eschels - EFSEC JB Martin NRC RV NS Reynolds - BCP8R RB Samworth - NRC DL Hilliams - BPA/399 NRC Site Inspector - 901A

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