ML17289A408

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Documents Granting of Temporary Waiver of Compliance from Surveillance Requirements of TS 4.6.6.1.b.3,per . Waiver Allows Plant to Utilize Different Criteria for Determining Operability of Hydrogen Recombiner Sys
ML17289A408
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 03/19/1992
From: Virgilio M
Office of Nuclear Reactor Regulation
To: Sorensen G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
NUDOCS 9203250321
Download: ML17289A408 (9)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 19, 1992 Docket No. 50-397 Mr.'. C. Sorensen, Manager Regulatory Programs Washington Public Power Supply System 3000 George Washington Way P.

O.

Box 968

Richland, Washington 99352

SUBJECT:

TEMPORARY WAIVER OF COMPLIANCE TO WASHINGTON NUCLEAR PROJECT)

UNIT 2 TECHNICAL SPECIFICATION 4. 6. 6. 1. b. 3, CONTAINMENT ATMOSPHERE CONTROL This letter documents the granting of a temporary waiver of compliance to the Washington Public Power Supply System (Supply System) for Washington Nuclear Project, Unit 2 (WNP-2) Operating License, NPF-21 'pecifically, this action authorizes a waiver of compliance from the surveillance requirements of Technical Specification (TS) 4.6.6. 1.b.3.

Your letter of March 13,

1992, (GO2-92-061) which was transmitted electronically to both Region V and this office, provided the basis for the temporary waiver of compliance.

This waiver was verbally granted at 4:45 PM,

PST, on March 13,
1992, by NRC's Office of Nuclear Reactor Regulation (NRR), with the concurrence of NRC's Region V Office.

This waiver allows WNP-2 to utilize a different criteria for determining the operability of the hydrogen recombiner system.

If the waiver of compliance were not approved, then WNP-2 would remain shutdown until the processing of a TS reflecting appropriate acceptance criteria for the hydrogen recombiner system could be completed.

The waiver involves the operability of the drywell and suppression chamber hydrogen recombiner systems.

TS 3. 6.6.

1 contains a surveillance requirement (TS 4.6.6. 1.b.3) which requires a certain level of performance of the system during the recombiner system functional test (required within an 18 month periodicity).

In particular, upon introduction of 1X by volume hydrogen in a 140-180 scfm stream containing at least 1X by volume oxygen, the catalyst bed temperature must rise by at least 120 F within 20 minutes.

If this operability test is not met for either of the two redundant hydrogen recombiner

systems, then the affected system is declared inoperable, and a

30 day Limiting Condition for Operation (LCO) goes into effect. If the plant is in a shutdown condition, as is currently the case, and a hydrogen recombiner system fails to meet its operability requirements, then in accordance with TS 3.0.4, the plant may not enter an operational condition (conditions 1 and 2) that requires both of the hydrogen recombiner systems to be operable.

NRR performed an evaluation of your written documentation and found it justified the basis for your request for a temporary waiver of compliance.

'9203250321 920319 PDR ADOCK 05000397 P

PDR

Mr>. G.

C. Sorensen The Supply System has determined that an appropriate acceptance criterion would be to measure the level of hydrogen in the effluent, in particular, 25 parts per million (ppm) hydrogen would be considered an acceptable measure of satisfactory recombiner operation.

Also, the Supply System states that an effluent reading of 10 ppm hydrogen at the effluent would be indicative of a 99.99K efficiency factor, which is a much more stringent standard than temperature rise alone.

Both of the recombiners were tested (March 12 and

13) using both the temperature rise and ppm criteria.

Train B showed a

120~F temperature rise within the 20 minutes as well as a

6 ppm hydrogen concentration in the effluent.

Train A failed to meet the temperature rise requirement, though it too had only a 6

ppm hydrogen concentration in the effluent.

The Supply System conducted additional tests with a 2X hydrogen concentration, and found that both recombiners showed a temperature rise proportional to the increase in hydrogen.

Importantly, during each operational test, the major portion of the temperature rise occurred in the top portion of the catalyst

bed, which is further evidence that the recombiners were operating properly.

Based on these test results, the staff agrees with the Supply System that both hydrogen recombiner systems are fully operational.

The staff has reviewed the Supply System's bases for determining that granting of the waiver of compliance will not involve any significant hazards condition or irreversible environmental considerations, and has found them acceptable.

We understand that the Supply System will submit an exigent TS request on or before March 18,

1992, in order to formally request an amendment to TS for this particular surveillance requirement.

This temporary waiver of compliance is considered to be in effect until the applicable TS amendment is fully processed.

If your understanding of this matter differs from that expressed

above, or if you have any questions regarding this matter, please contact me.

Sincerely, Hartin J. Virgilio, Assistant Director for Regions IV and V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation cc:

See next page

Mr.

G ~

C ~ Sorensen March 19, 1992 Thb Supply System has determined that an appropriate acceptance cr1terion would be to measure the level of hydrogen in the effluent, in particular, 25 parts per million (ppm) hydrogen would be considered an acceptable measure of satisfactory recombiner operation.

Also, the Supply System states that an effluent reading of 10 ppm hydrogen at, the effluent would be indicative of a 99.99K eff1ciency factor, which is a much more stringent standard than temperature r1se alone.

Both of the recombiners were tested (March 12 and

13) using both the temperature rise and ppm criter1a.

Train B showed a

1200 temperature ris@

within the 20 minutes as well as a

6 ppm hydrogen concentration in the effluent.

Train A failed to meet the temperature rise requirement, though it too had only a 6

ppm hydrogen concentration in the effluent.

The Supply System conducted additional tests with a 2X hydrogen concentration, and found that both recombiners showed a temperature rise proportional to the increase 1n hydrogen.

Importantly, during each operat1onal

test, the major portion of the temperature rise occurred in the top portion of the catalyst
bed, which is further evidence that the recombiners were operating properly.

Based on these test results, the staff agrees with the Supply System that both hydrogen recombiner systems are fully operational.

The staff has reviewed the Supply System's bases for determining that granting of the waiver of compliance will not involve any significant hazards condition or irreversible environmental considerations, and has found them acceptable.

We understand that the Supply System will submit an exigent TS request on or before March 18, 1992, in order to formally request an amendment to TS for th1s part1cular surve1llance requirement.

This temporary waiver of compliance is considered to be in effect until the applicable TS amendment is fully processed.

If your understanding of this matter differs from that expressed

above, or if you have any questions regarding this matter, please contact me.

Sincerely, Original Signed i3y:

Mart1n J. V1rgil1o, Ass1stant D1rector for Regions IV and V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation cc:

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Mr. G.

C. Sorensen WPPSS Nuclear Project No.

2 Washington Public Power Supply System (WNP-2)

CC:

Hr. J.

W. Baker WNP-2 Plant Manager Public Power Supply System P.O.

Box 968, HD 927M

Richland, Washington 99352 G.

E.

C.

Doupe, Esq.

Washington Public Power Supply System 3000 George Washington Way P.

O.

Box 968, HD 396 Richland, Washington 99532 Mr. R.

G. Waldo, Chairman Energy Facility Site Evaluation Council Mail Stop PY-11 Olympia, Washington 98504 Hr. Alan G. Hosier, Licensing Manager Washington Public Power Supply System P. 0.

Box 968, MD 956B

Richland, Washington 99352 Hr. A. Lee Oxsen, Assistant Managing Director for Operations Washington Public Power Supply System P.

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Box 968, MD 1023 Richland, Washington 99352 Hr. L. L. Grumme, Acting Director Licensing and Assurance

~ 0 Washington Public Power Supply System P.

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Box 968, MD 280

Richland, Washington 99352 Regional Administrator, Region V

UPS. Nuclear Regulatory Commission Washington 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Chairman Benton County Board of Commissioners P.

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Box 190

Prosser, Washington 99350-0190 Hr.

R.

C. Sorensen U. S. Nuclear Regulatory Commission P.

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Box 69

Richland, Washington 99352 Nicholas S. Reynolds, Esq.

Winston 8 Strawn 1400 L Street, N.W.

Washington, D.C.

20005-3502

Mr. G.

C. Sorensen Tive Supply System has determined that an appropriate acceptance cr1te ion would be to measure the level, of hydrogen in the effluent, in parti

lar, 25 parts per million (ppm) hydrogen would be considered an acceptable easure of satisfactory recombiner operation.

Also, the Supply System state that an effluent reading of 10 ppm hydrogen at the effluent would be ind cative of a 99.99K efficiency factor,"which is a much more stringent stand d than temperature rise alone.

Both of the recombiners were'tested (March 12 and

13) usin both the temperature r1se and ppm cr1teria.

Train B showed a

120 gree temperature rise within the 20 minutes as well as a

6 ppm hydrogen c ncentration in the effluent.

Train A failed to meet the temperature r1se equirement, though it too had only a 6

ppm hydrogen concentration in the eff uent.

The Supply System conducted additional tests with a 2X hydrogen oncentration, and found that both recombiners showed a temperature rise pro ortional to the increase in hydrogen.

Importantly, during each operational test, the major portion of the temperature rise occurred in the top portio of the catalyst

bed, which is further ev1dence that the recomb1ners were o erat1ng properly.

Based on these test results, the staff agrees with the upply System that both hydrogen recombiner systems are fully operat1onal.

The staff has reviewed the Supply System's ases for determining that grant1ng of the waiver of compliance will not invo ve any significant hazards condition

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or irreversible environmental considera

ons, and has found them acceptable.

We understand that the Supply System w

1 submit an emergency TS request on or before March 18, 1992, in order to fo mally request an amendment to TS for th1s particular surveillance require ent.

If your understanding of this mat er differs from that expressed

above, or if you have any questions regarding this matter, please contact me.

Sincerely, Martin J. Virg111o, Assistant Director for Regions IV and V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation cc:

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.The Supply System has determined that an appropriate acceptance criteri9

~ 'ould be to measure the level of hydrogen in the effluent, in particulp'r, 25 parts per million (ppm) hydrogen would be considered an acceptable measure of

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satisfactory recombiner,,operation.

Also, the Supply System states hat an effluent reading of 1.0 ppm hydrogen at the effluent would be indic tive of a 99.99K efficiency factor, which is a much more stringent standar than temperature rise alone..

Both of the recombiners were tested (March 12 and

13) using ot the temperature rise and ppm criteria.

Train B showed a

120 emperature rise within the 20 minutes as well as a

6 ppm hydrogen co centration in the effluent.

Train A failed to meet the temperature rise r qui rement, though it too had only a 6

ppm hydrogen concentration in the effluent.

The Supply System conducted additional tests w1th a 2X hydrogen<doncentration, and found that both recombiners showed. a temperature r1se proportional to the 1ncrease 1n hydrogen.

Impor ply, dur1ng each.,operationa)~test, the major portion of the temperature ri e ccurred in the top portioy of the catalyst

bed, which is further evidenc t the recombiners were operat1ng properly.

Based on these test results, the staff agrees with the Supply System that both hydrogen recombiner systems are fully operational.

The staff has reviewed the Supply Systems bases for determining that granting of the waiver of compliance will not involve any significant hazards condition or irrevers1ble environmental considergtions, and has found them acceptable.

We understand that the Supply System<kill submit an exigent TS request on or before March 18, 1992, in order to>formally request an amendment to TS for this part1cular surveillance requ)rement.

Th1s temporary waiver of compl1ance is considered to be in effect until the applicable TS amendment is fully processed.

If your understanding of thPs matter d1ffers from that expressed

above, or if you have any questions reg rding th1s matter, please contact me.

S1ncerely, Hart1n J. V1rgilio, Assistant D1rector for Regions IV and V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation cc:

See nex DISTRIBUTION Docket Fil FHiragli JGagliq do OGC(1 B18)

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