ML20137Q254
| ML20137Q254 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/1997 |
| From: | NRC |
| To: | NRC |
| References | |
| NUDOCS 9704100187 | |
| Download: ML20137Q254 (2) | |
Text
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April 4. 1997- . ,
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3 r i MEETING NOTICE 1 . ,_ ,
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- Organization: Private Fuel Storage LLC s
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Date and Time: April 24, 1997, 1:00 !,4i00 pm i H ~-*
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.. 1,7 ,a-Location: U.S. Nuclear Regulatory Commjssion * .,' .
u - A ~1 One White Flint North. , ' O. ; '! 'n ,
11555 Rockville Pike s .W
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4 ' :i' ' ei Rockville. Maryland 20852 ! ~. _ i', ., -
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Conference Room: WFNJ07-A-1 ~' 4 s./ '.
Purpose:
TodiscusssitingaspectsEf'the5pplication'forthe .
proposed Private Fuel Storag'e Independent Spent Fuel. Storage.
Installation. :
Participants:
NRC Private Fuel Storaae W. Kane John D. Parkyn C. Haughney . Jay Silberg, et. al.
E. Leeds F. Sturz M. Delligatti, et al .
NOTE: Meetings between the NRC staff and potential applicants are o)en for interested members of the public to attend as o) servers pursuant to the "Open Meeting Statement of NRC Staff Policy," 59 Federal Reaister 48340. 09/20/94.
Portions of this meeting may be closed to members of the -
public due.to the sensitive nature of information to be discussed pursuant to 10 CFR 2.790. ,
Contact:
Mark S. Delligatti, NRC/NMSS/SFP0 (301) 415-8518 ;
cc: Participants (fax copy)
Distribution
.- NRC' File :gente r' l .i 'PUBLIC. HMSS r/f SFI0 r/f SPTR/SFLS Staff (e-mail)
PMNS'(e-mail) WReamer, OGC SGagner, OPA WReckley, NRR WKane TCombs, OCA CHaughney PEng. 'SShankman EEaston JJankovich P8turs SDroggitis, OSP- BSpitzberg, RIV OFC SEP$ps /[T) C SFP k q') / C SFPO / C MAME MDell gat in VTha e EJLeeds IETE ' 04/djV/97 04 /#(/ /97 04/ / $
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-$- AGENDA l Meeting of the Spent Fuel Project Office Staff : ;
And Representatives of Private Fuel Storage, L.L.C.
April 24,1997 2
-1:00.PM_ L0pening Remarks NRC/PFS Purpose of the Meeting PFS Regulatory Licensing Basis PFS Siting Studies Performed PFS Description of Regional / ,
Siting Area Geology PFS l Description of Seismotectonic Setting PFS Deterministic Analysis PFS 4:00 Closing Remarks NRC/PFS 1
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Mr.~J. V. Parrish- April 7, 1997 cc w/ encl: , _
.Mr. Greg 0.: Smith (Mail Drop 927h) Mr. Rodney L. Webring (Mail Drop PE08) r WNP-2 Plant General Manager Vice President, Operations Support /PIO Washington Public Power Supply System- Washington Public Power Supply System P. 0. Box 968 P. O. Box 968 Richland,. Washington 99352-0968 Richland, Washington 99352
' Mr. Al E; Mouncer (Mail D' rop 396) Ms. Lourdes C. Fernandez (Mail Drop PE20) I Chief Counsel Manager, Licensing Washington Public Power Supply System Washington Public Power Supply System ,
P.O. Box 968 .
P. O. Box 968 Richland, Washington 99352-0968 Richland, Washington 99352 Mr. Frederick S. Adair, Chairman Energy Facility Site Evaluation Council P. 0. Box 43172 ,
Olympia, Washington 98504-3172 Mr. David A. Swank (Mail Drop PE20)
Manager, Regulatory Affairs Washington Public Power Supoly System P.O. Box 968 Richland, Washington 99352-0968 i Mr. 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 '
l U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 .
Arlington, Texas 76011-8064 l Chairman
- Benton County Board of Comissioners
. P.O. Box 69 Prosser, Washington 99350-0190 Mr. R. C. Barr, Senior Resident Inspector U.S. Nuclear Regulatory Comission P.O. Box 69 Richland, Washington '99352-0968 )
!- M.LH.:Philips, Jr., Esq.
Winston & Strawn 1400 L Street, N.W.
, Washington,;DC 20005-3502 L i
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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) .iu the f acility'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 Modes. The licensee states that there are no design basis events which credit ECC5 during Modes 4 and 5. i 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 P .rurveillance testing requirements in Technical Specifications had been satisfied. The failure to satisfy the response time testing requirement'
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.i 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 1etter 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 perform 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 HUREG-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 Reaister.
Following an initial review of this application against the standards in
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10 CFR 50.92, the NRC staff has made a proposed (preliminary) determination that the amendment request involves no significant hazards consideration.
L According to 10 CFR 50.92(c), this means that the proposed amendment would not c
involve a significant increase in the probability or consequences of an n
. r 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 purposra 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 s Emergency Core Cooling System (ECCS). However, because of the continued application of other existing Technical e Specification required testing such as channel calibrations, channel checks, thannel functional tests [CFTs], and logic system functional tests [UiFTs), 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 doec 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' Group Licensing .
Topical Report, NED0-32291-A, " Systems Analysis for the Elimination l of Selected Response Time Testing Requirements," October 1995] :
evaluation demonstrates that response time testing is redundant to i the other Technical Specification required testing listed in the i
- 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-011 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 i response time testing are also detected by other Technical l
- Spacification tests. i In addition, two categories of components were included in this !
- change in testing methodology which were not identified in the table of components in Reference 1. These components are used within the )
logic circuits addressed in Reference 1. These comnonents were !
inadvertently omitted from lists provided to General Electric in support of preparation of the Reference 1 tables.
These components have been reviewed for similarity to the items ]
contained within the Reference 1 component tables and have been i
- found to be similar to other equipment referenced in the table. (
These components 1re also subject to periodic functional testing by
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CFTs and LSFTs. The Supply System verified instrument response of these components at an appropriate interval using the alternate '
methodology for instrument verification described in Reference 1..
The two categories of components referenced above which are not included in the Reference I component list have no postulated i functions or affects 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 1 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 nc 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 1 i
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 i kind of accident. As a result, no new failure modes are introduced. i The two categories of components referenced above which are not i included-in the Reference I component list have no postulated i
- functions or affects which may contribute to the initiation of an accident. 1 i
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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 MODES 4 and 5. These changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. 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 altarnate methodology for instrument response verification (Reference 1) 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 1 component list are qualitatively tested periodically by channel calibrations, CFTs and LSFTs. This testing verii?ies the proper function and response of these components.
Adegaate time margins have been verified to be available within the applicable analyses which enable qualitative assessment of the proper performance of these devices.
Delating the requirement to verify response times for ECCS during MODES 4 and 5 will not affect the capability of the associated sys.tems 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 amendment without first offering an opportunity for a public hearing. An opportunity for hearing will be published in the Federal Reoister at a lator date and any hearing request will not delay the effective date of the amerdment.
I
e 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 Reaister and, if a hearing is granted, it will be held before the amendments are issued.
Coments on the proposed determination of no significant hazards consideration may be submitted to William Batoman, 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 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 Ccmission, Washington DC 20555-0001. Written coments may also be delivered to Room 6022, Two 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 coments received by 4:15 p.m. Eastern Daylight Savings Time on April 14, 1997, erill 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 Comission's Public Document Room.
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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 Reaister 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 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 6022, Two 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 final 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.
- For previous concurrences see attached ORC i
Document Name: WNPNSHC 0FC PDIV-2/PM PDIV-2/LA OPA* OGC* PDIV-2/D* I NAME TColburn EP N n JGilliland RBachmann WBateman 1
DATE 4/ /97 4f7 /97 4/7/97 4/4/97 4/7/97 0FFICIAL RECORD COPY
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