ML17290A185

Application for Amend to License NPF-21,changing TS Covering Implementation of ISI Program for Austenitic Stainless Steel Piping,Per GL 88-01

ML17290A185
Person / Time
Site:	Columbia
Issue date:	04/01/1993
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17290A186	List: ML17290A185 ML17290A187
References
GL-88-01, GL-88-1, GO2-93-076, GO2-93-76, NUDOCS 9304140007
Download: ML17290A185 (9)

Text

ACCEI ERAT DOCUMENT DIST UTION SYSTEM REGULAT INFORMATION DISTRIBUTIO YSTEM (RIDS)

ACCESSION NBR:9304140007 DOC.DATE: 93/04/01 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,changing TS covering implementation of ISI program for austenitic stainless steel piping,per GL 88-01.

DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief from ASM Code NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 1 1 CLIFFORD,J 2 2 INTERNAL: ACRS 6 6 NRR/DE/EMEB 1 1 NUDOCS-ABSTRACT 1 1 OC/LFMB 1 0 OGC/HDS1 1 0 ~REGMHgh 01 1 1 RES MILLMAN,G 1 1 DEB/DSIR/EIB 1 1 EXTERNAL: EG6rG BROWN,B 1 1 EG&G RANSOMEgC 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 18

0 0 WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Rtcbland, Wasbtngton 99352<96'8 ~ C509) 372-5000 April 1, 1993 G02-93-076 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS IN ACCORDANCE WITH GENERIC LETTER 88-01

References:

1) Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping"

2) Letter G02-92-241, dated October 16, 1992, GC Sorensen (SS) to NRC, "Response to Generic Letter 88-01"

3) Letter, dated January 19, 1993, JW Clifford (NRC) to GC Sorensen (SS)

"Alternate Schedule for IGSCC Inspections (TAC No. M84714)"

4) Letter, PL Eng (NRC to GC Sorensen (SS), dated December 28, 1990, "Response to GL 88-01, Intergranular Stress Corrosion in Piping (TAC No. 69161)"

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 WNP-2 Technical Specifications.

Generic Letter 88-01 provides guidance for the changes to the Technical Specifications concerning implementation of an Inservice Inspection (ISI) Program for austenitic stainless steel piping in conformance with the staff position. In Reference 3, the NRC approved the use of an alternative measure, allowing the inspection of Category D and E welds to be conducted every three years. Changes to the following Technical Specifications are being requested:

4.0.5 Applicability, Surveillance Requirements B 3/4.0.5 Applicability 1305 00 9304140007 930401 PDR ADOCK 05000397 Poa

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4

Page Two REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS IN ACCORDANCE WITH GENERIC LETTER 88-01 In addition, an editorial change is being requested for 3.4.3.2.d. The reference to Table 3.4.3.2-1 for the high/low pressure interface valve leakage pressure monitors is incorrect. This information is provided in Table 3.4.3.2-2.

This request for an amendment to the Technical Specifications also completes the Supply System response to the four open items discussed by the NRC in Reference 4.

The Supply System has reviewed the changes per 10 CFR 50.92 and provides the following in support of a finding for no significant hazards consideration. In fact, these changes being made in accordance with the Generic Letter issued by the NRC represent additional restrictions on the operation of WNP-2.

1) The changes to the ISI program do not involve a significant increase in the probability or consequences of an accident previously evaluated because inspections are not assumed as the initiator of any analyzed event, The increased surveillance requirements for inspections may facilitate early detection of a failure associated with IGSCC and serve to mitigate the consequences of such a failure, thereby enhancing safety.

2) The changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed changes do not introduce any new mode of plant operation or require any physical modification to the plant.

3) There is no reduction in a margin of safety due to these changes because the additional inspections have been established to assure the earliest possible detection of problems with or the need of repair or replacement of piping that may be susceptible to failure due to IGSCC.

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. The change will involve an increase in individual and cumulative occupational radiation exposure. As discussed in Reference 2, the nozzle inspection during R7 resulted in approximately 57 man rem of exposure, The approved alternative to GL 88-01 will require certain inspections to be completed every 3 years, compared to the original ISI Program requirement of every 10 years. This could result in exposure increase of 150 man rem in each 10 year inspection cycle. The Supply System does not believe this change represents a significant increase in the occupational exposure. Also, this change will be less than would be seen if the inspection were completed every 2 years as specified by the Generic Letter. Accordingly, the proposed change meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and an environmental assessment of this change is not required, per 10 CFR 51.22(b).

~ ~

Page Three REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATIONS IN ACCORDANCE WITH GENERIC LETTER 88-01 The change in the table reference is administrative and has no impact on the plant or plant operations.

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). In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.

Sincerely, G. C. So nsen, Manager Regulatory Programs (Mail Drop PE20)

MGE/bk Attachments CC: JB Martin - NRC RV NS Reynolds - Winston & Strawn JW Clifford - NRC DL Williams - BPA/399 NRC Site Inspector - 901A W Bishop EFSEC

STATE OF WASHINGTON )

Subject:

Request for Amend to TS

) In Accordancewi h L88- 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 PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that I have the 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 9/ f , 1993 G. C. Sor sen, Manager Regulatory Programs On this date 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 my hand and seal this ~day of 1993.

No Publicina d for t e STATE OF WASHINGTON Residing at Kennewick W hin n MyC i i Epi ~2

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