ML17285B023

Application for Amend to License NPF-21,changing Tech Spec 3.4.2 Re Safety Relief Valve & Tables 3.3.7.5-1 & 4.3.7.5.-1 Re Accident Monitoring Instrumentation to Permit Acoustic Monitor to Be Inoperable Until Next Shutdown

ML17285B023
Person / Time
Site:	Columbia
Issue date:	02/14/1990
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17285B024	List: ML17285B023 ML17285B025
References
GO2-90-025, GO2-90-25, NUDOCS 9002230437
Download: ML17285B023 (12)

Text

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BUTION DEMON STR~-IO'.i SYSTEM REGULATO INFORMATION DISTRIBUTION LITEM (RIDS)

ACCESSION NBR:9002230437 DOC.DATE: 90/02/14 NOTARIZED: YES DOCKET 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-21.Amend adds notes to Tech Specs 3.4.2 on emergency basis.

DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR J ENCL J SIZE: Q TITLE: OR Submittal: General Distribution D

NOTES:

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WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 February 14, 1990 G02-90-025 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2, OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3.4.2 (SAFETY RELIEF VALVES) AND TABLES 3.3.7.5-1 AND 4.3.7.5-1 (ACCIDENT MONITORING INSTRUMENTATION) UNDER EMERGENCY CIRCUMSTANCES

Reference:

Letter, G02-89-221, GC Sorensen (SS) to NRC, "Request for Amendment to Technical Specification 3.3.7.5 for Safety Relief Valve Position Indication" dated 12/4/89 In accordance with the Code of Federal Regulations, Title 10, Parts 50.90, 2. 101, and 50.91(a)(5), the Supply System hereby submits a request for amendment to the WNP-2 Technical Specifications on an emergency basis as provided for in the regulations. Specifically, the Supply System is requesting that notes be added to Specification 3.4.2, Safety Relief Valves and to Tables 3.3.7.5-1, Accident Monitoring Instrumentation, and 4.3.7.5-1 Accident Monitoring Instrumentation Surveillance Requirements to allow a single acoustic monitor on each of two SRVs to be inoperable until the plant shuts down for its next scheduled refueling outage or until the first forced outage of sufficient duration to effect repair, whichever occurs first (see attached).

Action C for Specification 3.4.2, Safety Relief Valve and action 80.a for Technical Specification Table 3.3.7.5-1, Accident Monitoring Instrumentation, require that the plant be shutdown if an inoperable indicator channel is not restored to operable status within seven (7) days. Due to apparent failure of the Acoustic Monitor for MS-RV-2D, the Supply System entered the seven day LCO at 1727 hours0.02 days <br />0.48 hours <br />0.00286 weeks <br />6.571235e-4 months <br /> on February 13, 1990. It has been determined that the plant will, be required to be shutdown and cooled down in order to repair/replace this acoustic monitor, unless an amendment is granted to allow the Supply System to continue to operate until either the next forced outage or the next scheduled outage (R-5).

Additionally, the acoustic monitor for MS-RV-2C is exhibiting characteristics similar to those observed on the MS-RV-2D acoustic monitor prior to its failure.

From these similar observations it has been concluded that a similar failure of the acoustic monitor for HS-RV-2C is likely. For this reason relief is requested for both acoustic monitors.

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l Page Two RE(VEST FOR AMEND. TO TS 3.4.2, SAFETY RELIEF VALVES AND TABLES 3.3.7.5-1 AND 4.3.7.5-1 ACCIDENT MONITORING t

INSTRUMENTATION UNDER EMERGENCY CONDITIONS As discussed in the reference the Supply System has made modifications to the acoustic monitors and changed procedures to increase the reliability of the monitors. This effort is ongoing. A design change is in progress that would allow accessibility, without plant shutdown, of the suspected failed component pending successful environmental qualification. The signal amplifiers (suspected component) and associated cabling for these monitors with the exception of 20 have been replaced. The monitor for MSRV-2D is scheduled to be replaced at the next outage. Further a Vendor representative site visit has been requested to assist in identifying additional enhancements to system reliability. The Supply System has been and is continuously working to improve this system.

The operability of the accident monitoring instrumentation is based on providing assurance that sufficient information is available on selected plant parameters (e.g., SRV position indication) to monitor and assess important variables following an accident. TMI Action Plan Item II.D.3 "Direct Indication of Relief and Safety-Valve Position" requires that "reactor coolant system relief and safety valves shall be provided with a positive indication in the control room derived from a reliable valve-position detection device or a reliable indication of flow in the discharge pipe." The technical specifications for WNP-2 require two instrumentation channels for providing this information on valve position.

One channel utilizes an acoustic monitor. The second channel utilizes thermocouples to detect a temperature increase indicative of flow past the valve.

The loss of either channel on one or more SRVs does not prevent accurate determination of the position of the associated SRV(s). Further, should an SRV open and remain stuck open, the resulting transient does not represent the same magnitude of challenge to a BWR (such as WNP-2) as does a stuck open pressurizer relief or safety valve on a PWR. As discussed in the safety analysis of this event (WNP-2 FSAR 15. 1.4), the operator response to this event is based on a suppression pool temperature alarm not an open alarm from the SRV position indication instruments. The mitigating actions are to attempt to close the open SRV and establish suppression pool cooling within 20 minutes. As discussed in this analysis even if the valve fails to close (worst case) the consequences of the event are mild. Hence the failure of an acoustic monitor causing an operator to review other instrumentation (as listed below) to determine which valve is open does not increase the severity of the transient. The valve can remain open.

The loss of position indication for one or more of the eighteen (18) Safety/

Relief Valves does not reduce the capability of the SRV to perform its intended function, nor does it prevent accurate determination of the position of the associated SRV.

The following mitigating and compensatory factors provide assurance that the valve position is adequately monitored:

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Page Three REQUEST FOR AMEND. TO TS 3.4.2, SAFETY RELIEF VALVES AND TABLES 3.3.7.5-1 AND 4.3.7.5-1 ACCIDENT MONITORING t

INSTRUMENTATION UNDER EMERGENCY CONDITIONS

1) Tail pipe temperature indication is monitored and recorded. An increase in temperature would indicate that the valve is open, and steam was entering the suppression pool via the tail pipe. This indication has remained capable of indicating valve actuation since the failed monitor was identified. Channel checks of the temperature recorder are currently performed monthly per LCO 3/4.3.7.5. Until the acoustic monitors for HSRV-RV-2C and 2D are declared operable, the tail pipe temperature surveillance will be performed daily instead of monthly. (See proposed change to Table 4.3.7.5-1 attached.) A control room annunciator is available that alarms on high tail pipe temperature (greater than 250'F).

An annunciator response procedure addressing the tail pipe temperature alarm will be revised to uniquely identify appropriate actions for HS-RV-2C and 2D.

2) Suppression Pool temperature indication is available, and is set to alarm at 85'F. An increase in suppression pool temperature would indicate an open SRV. This parameter will be monitored on a daily basis.

3) Suppression Pool level indication is available, and is set to alarm at

+0.5"/-1" of Normal Level (466'3"). An increase in suppression pool level would i,ndicate an open SRV. This parameter will be monitored on a daily basis.

4) Cross talk due to noise pickup from acoustic monitors on adjacent SRVs will indicate flow through the SRV with the failed monitor but will not alarm. This capability has been demonstrated to be a reliable diagnostic tool on several occasions in the past.

5) Other plant parameters are affected by an SRV actuation and are available as confirmation. Examples are main turbine governor valve position indication change, generator output change, main turbine steam flow change, steam/feedwater flow mismatch and the resultant reactor pressure perturbation.

Other indicators provide adequate feedback for ADS (reactor pressure) and SRV operation, and Alternate Shutdown Cooling operation (reactor pres-sure/temperature) if they are required. Additionally, MS-RV-2C and 2D are not controlled on either of the remote shutdown panels and are not ADS valves.

As was the failure of this acoustic monitor has only recently been identified, not possible for the Supply System to anticipate this event and submit this it request in a more timely manner. Based on the above and the following, no significant hazards consideration, the Supply System requests that the amendment as attached be granted until the next scheduled outage (no later than Hay 15, 1990), or the next forced outage of sufficient duration to effect the necessary repairs. Absent this amendment, the Supply System will be required to unnecessarily shutdown by February 20, 1990.

Page Four t REQUEST FOR AHEND TO TS 3.4.2, SAFETY RELIEF VALVES AND TABLES 3.3.7.5-1 AND 4.3.7.5-1 ACCIDENT HONITORING t

INSTRUHENTATION UNDER EHERGENCY CONDITIONS The Supply System has evaluated this amendment per 10CFR 50.92 and determined that it does not represent a significant hazard because it does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated because the SRV position indication channels are not assumed to function in the initiation of an analyzed accident.

The inoperability of these indication channels does not affect ADS operati'on of the SRVs. The analysis for an inadvertent opening of an SRV (FSAR Section 15. 1.4) assumes the function of these alarm-only instrument channels for the purpose of having the operator assess the need for commencing suppression pool cooling with RHR. As discussed above, the operator has many diverse indications available to indicate the need for commencing suppression pool cooling as a result of an open SRV and the SRV position indication is not the primary indication. Loss of an SRV position indication channel will not adversely affect the operator's ability to respond to this event as assumed in the analysis. The proposed change affects only the operability of the SRV position indication and does not affect automatic or manual actuation of the SRV. HSRV 2C and 2D are not ADS valves nor are they controlled from either of the remote shutdown panels (Appendix R). Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated because SRV operation, including the ADS function, remains unaffected. No new modes of operation of any equipment result due to this change. Sufficient diverse indication remains available to adequately determine whether an SRV is inadvertently open, therefore this change will not result in a failure to assess the need for suppression pool cooling. This change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Involve a significant reduction in a margin of safety because, as discussed above, the operator has many diverse indications available to indicate the need for commencing suppression pool cooling. Loss of an SRV position indication channel will not adversely affect the operator's ability to respond to this event as assumed in the analysis. The additional surveillances to monitor the suppression pool temperature while operation continues with an inoperable channel will compensate for the loss of position indication channel. Therefore, this change will not involve a significant reduction in the margin of safety.

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Page Five RE(VEST FOR AMEND. TO TS 3.4.2, SAFETY RELIEF VALVES AND TABLES 3.3.7.5- AND 4.3.7.5-1 ACCIDENT MONITORING t

INSTRUMENTATION UNDER EMERGENCY CONDITIONS 1

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 cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10CFR 51.22(c)(9) and therefore, per 10CFR 51.22(b), an environmental assessment of the change is not required.

This amendment request has been reviewed and approved by the WNP-2 Plant Operations Committee (POC) and the Supply System Corporate Nuclear Safety Review Board (CNSRB).

In summary, based on the assertion that no significant hazard is created by the subject relief and that remaining methods are available to satisfy the function of determining valve position, present operation does not represent an undue risk to the health and safety of the public. Additionally absent this amendment, the WNP-2 plant will be required to shutdown.

Very truly your ,

G. C. rensen, Manager Regulatory Programs PLP/bk Attachments CC: JB Hartin - NRC RV NS Reynolds - BCPER RB Samworth - NRC DL Williams - BPA/399 NRC Site Inspector - 901A C Eschels - EFSEC

Req. for Emergency TS change 3.4.2 8 STATE OF WASHINGTON )

Subject:

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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.

OATE , 1990 G. C. SO+ NS N, Manager 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 acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned.

GIVEN under ray hand and seal this ~lh day of ,1990.

o y ulcc in and or t e State of Washington i Residing at t

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