ML17290A892

Suppl to 930709 Application for Amend to License NPF-21, Increasing Licensed Power Level from 3,323 Mwt to 3,486 Mwt W/Extended Load Line Limit & Changing SRV Setpoint Tolerance to Include Changes to TS Paragraph 6.9.3.2

ML17290A892
Person / Time
Site:	Columbia
Issue date:	01/06/1994
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17290A893	List: ML17290A892 ML17290A894
References
GO2-94-004, GO2-94-4, NUDOCS 9401240255
Download: ML17290A892 (9)

Text

AC ELERATED DI RIBUTION DEMONST TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9401240255 DOC.DATE: 94/01/06 NOTARIZED: YES 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:

Application for amend to license NPF-21,requesting changes to TS by increasing licensed power level from 3323 MWT to 3486 MWT w/extended load line limit 6 change SRV setpoint tolerance. D DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PDV LA 1 1 PDV PD 1 1 CLIFFORD,J 2 2 D

INTERNAL: ACRS 6 -

6 NRR/DE/EELB 1 1 NRR/DORS/OTSB 1 1 NRR/l)RCH/HICB 1 1 NRR/DRPW 1 1 NRR/DSSA/SPLB 1 1 NRR/DS SA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OC/LFDCB 1 0 OGC/HDS1 1 0

<<BEG~PS 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 A

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37. (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 20

0 e r'

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Wasbtngton Way ~ Rtcbland, 1Pasbtngton 99352-09l28 ~ (509) 372-5000 January 6, 1994 G02-94-004 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 AMENDMENT TO FACILITY OPERATING LICENSE ANDTECHNICALSPECIFICATIONS TO INCREASELICENSED POWER LEVELFROM 3323 MWTTO 3486 MWT WITHEXTENDED LOAD LINE LIMIT AND A CHANGE IN SAFETY RELIEF VALVE SETPOINT TOLERANCE, SUPPLEMENTAL INFORMATION

Reference:

Letter G02-93-180, dated July 9, 1993, JV Parrish (SS) to NRC, same subject The reference requested a change to the WNP-2 License and several sections of the WNP-2 Technical Specifications and Bases to support implementation of a power uprate program with Extended Load Line. Limit and a change in Safety Relief Valve Setpoint Tolerance. Submitted with the reference, as supporting information for this request, was NEDC-32115P, "Washington Public Power Supply System Nuclear Project 2, SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis," Class III(Proprietary) Revision 2, July 1993. NEDC 32(15P was provided to confirm the adequacy of the ECCS under the requested uprate conditions. Inherent in the NEDC-32115P analysis were fuel performance specifications necessary to preserve the conclusions of the analysis. As such, the NEDC-32115P analytical methodologies used to assure that the ECCS uprate analysis is satisfied must be included in Technical Specification paragraph 6.9.3.2, which lists analytical references used to determine the core operating limits for each cycle reload. The need to include this information was not recognized at the time the reference was submitted.

Hence, in accordance with the Code of Federal Regulations, Title 10 Parts 50.90 and 2.101, this letter requests that the Technical Specification change submitted in the reference also include the changes to Technical Specification paragraph 6.9.3.2, see attached, necessary to ensure that reload cycles support the conclusions of NEDC-32115P. The addition of the two references is PDR p 'DR 940i240255 '2140i06

• DOCK 05000397

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Page Two REQUEST FOR AMENDMENT TO FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATIONS TO INCREASE LICENSED POWER LEVEL FROM 3323 MWT TO 3486 MWT WITH EXTENDED LOAD LINE LIMITAND A CHANGE IN SAFETY RELIEF VALVE SETPOINT TOLERANCE, SUPPLEMENTAL INFORMATION considered to be an administrative change. Both references have been previously reviewed and approved by the NRC. The addition of these two references imposes additional requirements to ensure that Core Operating Limits Reports (COLRs) preserve the ECCS conclusions of the uprate analysis.

The Supply System has evaluated the addition of these two references to Technical Specification paragraph 6.9.3.2 with respect to 10 CFR 50.92 and determined that it does not represent a significant hazards consideration because it does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated. Because the addition of these two references represents additional requirements to ensure that plant response to previously evaluated accidents remains within the design requirements of the uprate submittal, and the uprate submittal has been evaluated as not being a significant hazards concern, this change also does not involve a significant increase in the consequences of previously evaluated accidents. To the contrary, this change assures that the consequences of previously evaluated accidents will remain within the bounds of the analysis provided by the referenced uprate submittal.

Because the fuel performance specifications in the ECCS performance evaluation of the uprate submittal are not credited with initiating a previously evaluated accident the probability of a previously evaluated accident with or without this change remains the same. Therefore incorporation of these two references to the WNP-2 Technical Specifications willnot alter the probability, nor increase the consequences of a previously evaluated accident.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed additions introduce no new mode of plant operation nor do they require physical modification of the plant. The addition of these two references ensures that reload submittals remain bounded by appropriate analysis. Hence the possibility of a new or different kind of accident than those previously evaluated is not created by this change.

3) Involve a significant reduction in a margin of safety. Imposition of additional requirements to ensure that plant parameters remain within approved analyses does not create a reduced margin of safety. The addition of these two references ensures that the margin of safety created by the uprate analysis is not threatened. Imposition of these two references ensures that the reload analysis and fuel performance specifications will be

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Page Three REQUEST FOR AIVKÃDMENT TO FACILITY OPERATING LICENSE AND TKCHNICALSPECIFICATIONS TO INCREASE LICENSED POWER LEVEL FROM 3323 MWT TO 3486 MWT WITH EXTENDED LOAD LINE LIMITAND A CHANGE IN SAFETY RELIEF VALVE SETPOINT TOLERANCE, SUPPLEMENTAL INFORMATION bounded by the uprate analysis which has also been determined not to reduce a margin of safety. Accordingly, the addition of these two references, which willassure adherence to the uprate analysis assumptions and methodologies, likewise does not represent a significant reduction in a margin of safety.

As discussed above, the Supply System concludes that the addition of the two references to Technical Specification 6.9.3.2 does not involve a significant hazards consideration, nor is there a potential for a significant change in the types or significant increase in the amount of any effluents that may be released offsite, nor does the addition of these two references involve a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change adding the two references meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(C)(9) and therefore, per 10 CFR 51.22(b), an environmental assessment of this change is not required.

This Technical Specification change request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.

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

This submittal is considered to be of an administrative nature, supportive of the uprate submittal and it is requested that this change be reviewed and approved concurrently as supplemental information to that provided in the reference.

Sincerely,

. V. Parrish (Mail Drop 1023)

Assistant Managing Director, Operations PLP/bk Attachments CC: KE Perkins - NRC RV NS Reynolds - Winston & Strawn JW Clifford - NRC DL Williams - BPA/399 NRC Site Inspector - 927N W Bishop - EFSEC

STATE'OF WASHINGTON )

Subject:

Request for Amend to License & TS

) Pa h 2 COUNTY OF BENTON )

I. J. V. PARRISH, being duly sworn, subscribe to and say that I am the Assistant Managing Director, Operations 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 , 1994 J . Parrish, Assistant Managing Director Operations On this date personally appeared before me J. V. PARRISH, 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 1994.

No Public n and for the STATE OF WASHINGTON Residing at My Commission Expires

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