ML17292A782
| ML17292A782 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/07/1997 |
| From: | Colburn T NRC (Affiliation Not Assigned) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 9704100238 | |
| Download: ML17292A782 (15) | |
Text
~'pril7, 1997 Hr. J.
V. Parri sh Chi'ef Executive Officer Washington Public Power Supply System P.O.
Box 968 (Mail Drop 1023)
Richland Washin ton 99352-0968 g
SUBJECT:
PUBLIC NOTICE OF APPLICATION FOR AMENDMENT TO OPERATING LICENSE FOR WASHINGTON NUCLEAR PROJECT NO.
2 (WNP-2)
Dear Hr. Parrish:
The enclosed public announcement was forwarded to the Tri-City Herald for publication.
This announcement relates to your application dated March 22,
- 1997, as supplemented by letters dated April 2,
- 1997, and April 3, 1997, for an amendment to Facility Operating License No. NPF-21 for WNP-2.
A separate notice will be published later in the Federal
~Re ister concerning the license amendment.
Sincerely, Original Signed By Timothy G. Colburn, Senior Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-397
Enclosure:
Public Announcement cc w/encl:
See next page Document Name:
WNP.PUB DISTRIBUTION:
Docket
'UBLIC PDIV-2 Reading JRoe EGAl WBateman TColburn ACRS OGC OPA HLesar AHowell, Region" IV HWong, Region IV WCFO
- MHammond, Region IV WCFO BHenderson, Region IV gfDI OFC PDIV-2 NAME TColburn DATE 4 + 97
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Hr. J.
V. Parrish April 7, 1997 cc w/encl:
Hr. Greg 0. Smith (Mail Drop 927M)
WNP-2 Plant General Manager Washington Public Power Supply System P., 0.
Box 968
- Richland, Washington 99352-0968 Mr. Al E. Houncer (Mail Drop 396)
Chief Counsel Washington Public Power Supply System P.O.
Box 968
- Richland, Washington 99352-0968 Hr. Frederick S. Adair, Chairman Energy Facility Site Evaluation Council P. 0.
Box 43172 Olympia, Washington 98504-3172 Hr. David A. Swank (Mail Drop PE20)
- Manager, Regulatory Affairs Washington Public Power Supply System P.O.
Box 968
- Richland, Washington 99352-0968 Hr. Paul R.
Bemis (Mail Drop PE20)
Vice President, Nuclear Operations Washington Public Power Supply System P.O.
Box 968
- Richland, Washington 99352 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower 8 Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Chairman Benton County Board of Commissioners P.O.
Box 69
- Prosser, Washington 99350-0190 Hr.
R.
C. Barr, Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O.
Box 69
- Richland, Washington 99352-0968 H.
H. Philips, Jr.,
Esq.
Winston L Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 Hr. Rodney L. Webring (Hail Drop PE08)
Vice President, Operations Support/PIO Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352 Hs.
Lourdes C. Fernandez (Hail Drop PE20)
- Manager, Licensing Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352
PUBLIC NOTICE NRC STAFF PROPOSES TO AMEND THE OPERATING LICENSE FOR WASHINGTON NUCLEAR PROJECT NO.
2 The U.S. Nuclear Regulatory Commission (NRC) has received an application dated March 22,
- 1997, as supplemented by letters dated April 2,
- 1997, and April 3,
- 1997, from the Washington Public Power Supply System (the licensee) for an amendment to Facility Operating License No.
NPF-21 for the Washington Nuclear Project No. 2, located in Benton County, Washington.
The proposed amendment would revise surveillance requirements (SR) in the facility's Technical Specifications.
Specifically, SR 3.3. 1. 1. 15, Reactor Protection System (RPS)
Response
- Time, and SR 3.3.6. 1.7, Primary Containment Isolation System
Response
- Time, have notes added to clarify how the response time will be verified for certain functions.
SR 3.3.5. 1.7, Emergency Core Cooling System (ECCS)
Response
Time requirements would be relocated to new ECCS Operating System TS SR 3.5. 1.8.
The licensee would be using a previously staff approved alternative to response time testing for selected instrument sensors,and ECCS actuation instrumentation.
The licensee also requested that the Applicability for the ECCS actuation instrumentation be changed to Modes 1,
2 and 3, where currently it is required in all Hodes.
The licensee states that the're are no design basis events which credit ECCS during Modes 4 and 5.
The proposed amendment is submitted to resolve enforcement discretion which was issued to the licensee on March 21, 1997, to address non-compliance with the TS requirements.
The licensee provided the following discussion of the exigent circumstances for the amendment:
The staff indicated that the Supply System was in violation of Technical Specifications in a March 20, 1997, letter from T.
P.
Gwynn (NRC) to J.
V. Parrish (SS).
Prior to that, the Supply System believed the surveillance testing requirements in Technical Specifications had been satisfied.
The failure to satisfy the response time testing requirement
was not formally identified by the staff until March 20.
Consequently, it was not possible to submit this request on a more timely basis.
The NRC staff stated in its March 20, 1997 letter that the Supply System technical approach to verification of instrument operability is generally consistent with an approach the staff has found acceptable.
Therefore, the Supply System concluded there was less risk in relying on the existing response time verification method than commencing a plant shutdown in order to gain actual test, data in cold shutdown conditions.
Cold shutdown conditions would have been required to per'form the response time testing to resolve the violation of the Technical Specifications.
WNP-2 was placed in cold shutdown following the discretion requested by letter dated March 20,
- 1997, from J.
V. Parrish to the NRC.
The Supply System continues to believe the methodology used to verify response times requested in this submittal is preferable to measuring of response times because personnel will absorb less dose and the plant will experience a higher availability of safety systems during the shutdown.
Because the violation was only recently identified and the method currently used assures continued operability of the instrumentation, the Supply System is requesting this amendment under exigent circumstances.
The NRC enforcement policy contained in NUREG-1600, "General Statement of Policy and Procedures for NRC Enforcement Actions," dated July 1995, states that the issuance of enforcement discretion would be for the. brief period of time necessary to process an emergency or exigent Technical Specification change.
The NRC has determined that the licensee made a timely application for the proposed changes and that exigent circumstances do exist and were not the result of any intentional delay on the part of the licensee.
The licensee cannot change Modes to allow fuel movement until the amendment has been approved by the NRC and time does not allow for full notice in the Federal
~Re ister.
Following an initial review of this application a'gainst the standards in 10 CFR 50.92, the NRC staff has made a proposed (preliminary) determination that the amendment request involves no significant hazards consideration.
According to 10 CFR 50.92(c), this means that the proposed amendment would not'nvolve a significant increase in the probability or consequences of an
l
~
l
accident previously evaluated, would not create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
The licensee's analysis of the, no significant hazards consideration is presented below:
1.
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The purpose of the proposed license change is to eliminate response time testing requirements for selected instrumentation in the Reactor Protection System (RPS),
Primary Containment Isolation Actuation, and Emergency Core Cooling System (ECCS).
- However, because of the continued application of other existing Technical
'pecification required testing such as channel calibrations, channel
- checks, channel functional tests
[CFTs],
and logic system functional tests
[LSFTs], the response time of these systems will be maintained, within the limits assumed in plant safety analyses and required for successful mitigation of an initiating event.
The proposed license change does not affect the capability of the associated systems to perform their intended functions within the required response
- time, nor do the proposed changes affect the operation of any equipment.
The Reference 1
[GE Nuclear
- Energy, BWR Owners'roup Licensing
. Topical Report, NED0-32291-A, "Systems Analysis for the Elimination of Selected
Response
Time Testing Requirements,"
October 1995]
evaluation demonstrates that response time testing is redundant to the other Technical Specification required testing listed in the preceding paragraph.
This evaluation was reviewed and approved by the staff.
These other tests, in conjunction with actions taken in response to NRC Bulletin 90-01, "Loss of Fill-Oil in Transmitters Manufactured by Rosemount,"
and Supplement 1, are sufficient to identify failure modes or degradations in instrument response time and ensure operation of the associated systems within acceptable limits.
Furthermore, all known failure modes that are detected by response time testing are also detected by other Technical Specification tests.
In addition, two categories of components were included in this change in testing meth'odology which were not identi,fied in the table of components in Reference 1.
These components are used within the logic circuits addressed in Reference 1.
These components were inadvertently omitted from lists provided to General Electric in support of preparation of the Reference 1 tables.
These componehts have been reviewed for similarity to the items contained within the Reference 1 component tables and have been found to be similar to other equipment referenced in the table.
These components are also subject to periodic functional testing by
The Supply System verified instrument response of these components at an appropriate interval using the alternate methodology for instrument verification described in Reference l.
I The two categories of components referenced above which are not included in the Reference I component list have no postulated functions or'ffects which may cause an accident.
These devices are
. tested periodically to verify functionality.
Sufficient time margin is available in the station accident analysis to account for the amount of time delay allowed by the Reference I methodology.
For the changes dealing with moving the surveillance requirement for ECCS
RESPONSE
TIME testing from the Instrumentation section to the System section of the Technical Specifications, no change in testing requirements (other than the elimination of the instrument loops implemented as part of the Reference I change) has been introduced.
The relaxation in Applicability does not increase the probability or consequences of an accident previously evaluated, since there are no design basis events which credit ECCS during MODES 4 and 5.
Therefore, the proposed amendment request does not involve a
significant increase in the probability or consequences of an accident previously evaluated.
2.
The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment
- applies, in part, to the testing requirement for the components identified and does not result in any physical change to these or other components or their operation.
The changes do not affect the capability of the associated systems to perform their intended function within the acceptable limits assumed in plant safety analyses and required for successful mitigation of an initiating event.
The proposed amendment does not change the way in which any plant systems are operated or create the possibility of a new'or different kind of accident As a result, no new failure modes are introduced.
The proposed amendment also deletes the applicability of response time testing for ECCS systems during MODES 4 and 5.
This change in testing requirements does not change the way in which any plant systems are operated or create the possibility of a new or different kind of accident.
As a result, no new failure modes are introduced.
The two categories of components referenced above which are not included in the Reference I component list have no postulated functions or affects which may contribute to the initiation of an accident.
3.
The proposed amendment represents reliance on a different, and previously staff approved, method to verify selected components remain fully functional.
It also requests a reduction in test requirements for ECCS in NODES 4 and 5.
These changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change does not.involve a significant reduction in a margin of safety.
The current response times are based on the maximum allowable values assumed in the plant safety analyses.
These analyses conservatively establish the margin of safety.
As described
- above, the reliance on an alternate methodology for instrument response verification (Reference I) will not affect the capability of the associated systems to perform their intended function within the allowed response time used as the basis for the plant safety analyses.
The two categories of components referenced above which are not included in the Reference I component list are qualitatively tested periodically by channel calibrations, CFTs and LSFTs.
This testing verifies the proper function and response of these components.
Adequate time margins have been verified to be available within the applicable analyses which enable qualitative assessment of the proper performance of these devices.
Deleting the requirement to verify response times for ECCS during NODES 4 and 5 will not affect the capability of the associated systems to perform their intended'function within the allowed response time used as the basis for the plant safety analyses.
Plant and system response to an initiating event will remain in compliance with the assumptions of the safety analyses, and therefore the margin of safety is not affected.
If the proposed determination that the requested license amendment involves no significant hazards consideration becomes final, the NRC will issue the hearing.
amendment without first offering an opportunity for a public An opportunity for hearing will. be published in the Federal Re ister at a later date and any hearing request will not delay the effective date of the amendment.
If the NRC decides in its final determination that the amendment does involve a significant hazards consideration, a notice of opportunity for a prior hearing will be published in the Federal Re ister and, if a hearing is granted, it will be held before the amendments are issued.
Comments on the proposed determination of no significant hazards consideration may be submitted to William Bateman, Director, Project Directorate IV-2, by collect call to 1-301-415-1371 or by facsimile to 1-301-415-3861 or 1884.
Mritten comments may be submitted by mail to the Chief, Rules Review and Directives Branch, Division of Freedom of Information and Publications
- Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001.
Written comments may also be delivered to Room 6D22,'wo White Flint North, 11545 Rockville Pike, Rockville, Maryland, from 7:30 a.m. to 4: 15 p.m.
Federal workdays.
Copies of written comments received may be examined at the NRC Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC.
All comments received by 4: 15 p.m. Eastern Daylight Savings Time on April 14, 1997, will be considered in reaching a determination.
A copy of the application may be examined at the NRC's Local Public Document Room located at the Richland Public Library, 955 Northgate Street,
- Richland, Washington
- 99352, and at the Commission's Public Document Room.
If the NRC decides in its,final determination that the amendment does
)
involve a significant hazards consideration, a notice of opportunity for a prior hearing will be published in the Federal Re ister and, if a hearing is granted, it will be held before the amendments, are issued.
Comments on the proposed determination of no significant hazards consideration may be submitted to William Bateman, Director, Project Directorate IV-2, by collect call to 1-301-415-1371 or by facsimile to 1-301-415-3861 or 1884.
Written comments may be'ubmitted by mail to the Chief, Rules Review and Directives Branch, Division of Freedom of Information and Publications
- Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001.
Written comments may also be delivered to Room 6D22, Two White Flint North, 11545 Rockville Pike, Rockville,
- Maryland, from 7:30 a.m. to 4: 15 p.m.
Federa'I workdays.
Copies of written comments received may be examined at the NRC Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC.
All comments received by 4: 15 p.m.
Eastern Daylight Savings Time on April 14, 1997, will be considered in reaching a final determination.
A copy of the application may be examined at the NRC's Local Public
'I Document Room located at the Richland Public Library, 955 Northgate Street,
- Richland, Washington
- 99352, and at the Commission's Public Document Room.
- For previous concurrences see attached ORC OFC NAME TColburn EPeyeVn Document Name:
WNPNSHC P0 IV-2/PM PDIV-2/LA OPA*
JGilliland OGC*
RBachmann PD IV-2/D*
WBateman DATE 4+7 /97 4
97 OFFICIAL RECORD COPY 4/7/97 4/4/97 4/7/97
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