ML17290A697

Informs That Since Time of Submittal of Change Re Removal of MSL Radiation Monitor Scram & Isolation Valve Closure Functions from Ts,Util Identified Addl Impacts Change Would Have on Eops,W/Regard to Implementation of OL Amend 112

ML17290A697
Person / Time
Site:	Columbia
Issue date:	10/14/1993
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-93-252, TAC-M82061, NUDOCS 9310200330
Download: ML17290A697 (4)

Text

ACCELERATED DOCUMENT DISTRIBUTION SYSTEM REGULATLO INFORMATION DISTRIBUTIONISTEM (RIDE)

ACCESSION NBR:9310200330 DOC.DATE: 93/10/14 NOTARIZED: NO DOCKET FACIL:..50-397 WPPSS Nuclear Project, Unit 2, .Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PARRISH,J.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Informs that since time of submittal of change re removal of D MSL radiation monitor scram 6 isolation valve closure functions from TS,util identified addi impacts change would, have on EOPs,w/regard to implementation of OL Amend 112.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR J ENCL 0 SIZE:

TITLE: OR Submittal: General Distribution A NOTES:

D RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PDV LA PDV PD CLIFFORD,J INTERNAL: ACRS NRR/DE/EELB NRR/DORS/OTSB NRR/DRCH/HICB NRR/DSSA/SPLB NRR/DSSA/SRXB NUDOCS-ABSTRACT OC/AgD,CB OGC/HDS1 G FILE 01 EXTERNAL: NRC PDR NSIC NOTE TO ALL"RIDS" RECIPIENTS:

D PLEASE HELP US TO REDUCE WASTE! CONTACT TI.IE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DIS'I'l<I!3UT!ON D LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Bm 968 ~ 3000 George Wasbtngton Way ~ Richland, Wasbtngton 99352-0968 ~ (509) 372-5000 October 14, 1993 G02-93-252 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 IMPLEMEKI'ATIONOF OPERATING LICENSE AMENDMENT112 REGARDING REMOVAL OF MAINSTEAM LINE RADIATION MONITOR SCRAM AND ISOLATION VALVE CLOSURE FUNCTIONS FROM TECHNICAL SPECIFICATIONS (TAC NO. M82061)

References:

1) Letter, dated January 26, 1993, JW Clifford (NRC) to GC Sorensen (SS),

"Issuance of Amendment for the Washington Public Power Supply System Nuclear Project No. 2 (TAC No. M82061)"

2) NEDO-31331, dated March 1987, "BWR Owner's Group Emergency Procedure Guidelines," Revision 4, General Electric Company

3) Letter, dated September 12, 1988, AC Thadani (NRC) to Donald Grace (BWROG), "Safety Evaluation of 'BWR Owner's Group - Emergency Procedure Guidelines, Revision 4'EDO 31331, March 1987" By Reference 1, the NRC provided Amendment No. 112 to the WNP-2 Operating License providing for removal of the main steam line radiation monitor scram and isolation valve closure functions from the Technical Specifications.

Since the time of the submittal of this requested change, the Supply System and the BWROG have identified additional impacts the change would have on the Emergency Operating Procedures. Currently, Reference 2 takes credit for the main steam line isolation function as a barrier that limits release of radioactive material to the environment. This is acknowledged 9310200330 931014'i PDR'DOCK '05000397

~P PDR tip

Page Two IMPLEMENTATIONOF OPERATING LICENSE AMENDMENT 112 REGARDING REMOVAL OF MAINSTEAM LINE RADIATION MONITOR SCRAM AND ISOLATION VALVECLOSURE FUNCTIONS FROM TECHNICAL SPECIFICATIONS (TAC NO. M82061) in Reference 3. Page 44 of the SER states that "(i)fMSIVs are closed due to low RPV water level, the interlocks are bypassed to open the MSIVs (other interlocks such as isolation on high radiation are not bypassed)." If this barrier is removed or defeated, then a comparable barrier or action must be added to ensure protection against release of radioactive material.

At a meeting of the BWROG Emergency Procedure Committee-II March 31 - April 2, 1993, this issue was discussed and action was assigned to evaluate necessary changes to the EPGs.

The Supply System does not believe that it would be appropriate to process the required procedure changes to implement Amendment 112 solely under the provisions of 10CFR50.59.

We believe that an EPG change should be pursued through the BWROG to address the removal of these functions. Also, while the hardware aspects of this change could be implemented during power operation, we are reluctant to perform the required modifications in the cabinets containing the associated trip logic while at power. Therefore, to allow for the needed modifications to be completed during a scheduled outage, and to allow time for resolution of the EPG concerns through the BWROG, we plan to implement the change in the April 1994 refueling outage currently scheduled to be completed in June 1994.

Sincerely,

. V. Parrish (Mail Drop 1023)

Assistant Managing Director, Operations AGH/bk CC: BH Faulkenberry - NRC RV NS Reynolds - Winston & Strawn JW Clifford - NRC DL Williams - BPA/399 NRC Site Inspector - 901A

! 'Ny k