ML17278A457

Application for Amend to License NPF-21,revising Tech Specs to Allow Reactor Mode Changes W/Isolated Primary or Secondary Containment Isolation Valves W/No Degradation to Public Health & Safety.Fee Paid

ML17278A457
Person / Time
Site:	Columbia
Issue date:	10/28/1985
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Butler W Office of Nuclear Reactor Regulation
Shared Package
ML17278A458	List: ML17278A457 ML17278A459
References
GO2-85-740, TAC-60050, NUDOCS 8511040196
Download: ML17278A457 (9)

Text

i>> REGULATOR ORMATION DISTRIBUTION M (RIDS)

ACCESSION NBR:85110<0196 FACIL.:60. 397 WPPSS DOC ~ DATE: 8S/10/28 Nucl ear Pr oj ect i Uni t 2~

NOTaRIZKD: NO, Wash'ington Pub i c Powe" 1

DOCKET:, y 05000397 AUTH ~ NAIVE. AUTHOR AFFIL'IATION SORENSEN~G ~ CD Washington Public Power Supply System RKCIP',NAME>> RECIPIENT, AFFILIATION BUTLERgW,RI. Licensing Branch 2 SUBJECT; Appl ication for amend to License. NPF "21' evising Tech; Spe'cs'o allow reactor mode changes w/isolated primary of secondary containment isolation valves w/no degradation to-public health a,-safety.Fee:, paid, DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR '

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TITLE OR Submittal: General Distr ibuti on NOTES:. 05000397 OL 5 12'/20/83 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME>> LTTR ENCL>> ID CODE/NAME LTTR ENCL NRR LB2" BC 01 =-7 7 INTERNALS ACRS" 09. 6 6 ADM/LFMB 1 0 ELD/HDS2 1>> /0 NRR/DE/MTEB 1 NRR/DL D IR 1 1 NRR/DL/DRAB 1 0, NRR/DL/TSRG 1 1 /METB 1 NRR/DSI/RAB l. 1 0Q 1 1 RGN5 1 1 EXTERNALS 20X 1 1 EG8,G. BRUSKEp S LPDR 03>> 1 1 NRC'DR NSIC 05 1 1 a ~I 02'OTAL NUMBER'F COPIES'EQUIRED: LTTR 28 ENCL. 25

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Washington Public Power Supply System P.Q. Box 968 3000 George Washington Way Richland, Washington 99352 (509) 372-5000 October 28, 1985 G02-85-740 Docket No. 50-397 Director of Nuclear Reactor Regulation Nr. W. R. Butler, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

NUCLEAR PLANT NO. 2 OPERATING LICENSE NPF-21, RE(VEST FOR TECHNICAL SPECIFICATION AMENDMENT (3/4.6.3 and 3/4.6.5)

Reference:

None In accordance with the Code of Federal Regulations (CFR), Title 10, Parts 50.90 and 2.101, the Supply System hereby requests an amendment to Sections 3/4.6.3 (Primary Containment Isolation Valves), and 3/4.6.5 (Secondary Containment Integrity) of the WNP-2 Technical Specifications.

The proposed amendment will allow reactor mode changes with isolated primary or secondary containment isolation valves with no degradation to public health or safety.

This request is based on the Supply System's conclusion that plant operational condition changes with the specific component(s) inoperable but isolated, and with the associated system (primary/secondary contain-ment) operable, does.not affect plant safety.

Specification 3.0.4 is provided to "... ensure that unit operation is not initiated with either re~ui red equipment or systems inoperable or other limits being exceeded.'owever, exceptions are provided "...

when startup with inoperable'equipment would not affect plant safety."

In order to ensure that the primary containment meets its design func-tion, isolation valves are provided. The Technical Specification bases for 3.6.3 states "The OPERABILITY of the primary containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment."

Therefore, the intent of this specification is to ensure that all lines I

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Mr. W. R. Butler Page Two with isolation valves will be isolated if conditions exist which require the primary containment to perform this design function. This intent can be met by either an operable automatic isolation valve or a closed valve (or otherwise isolated line). Since plant safety is not degraded when an automatic isolation valve is inoperable, but secured in its isolated position per this specification, the issue related to opera-tional condition changes should be predicated on requirements other than primary containment integrity. The requirements are adequately covered by other LCO's when considering the effect action execution has on system operability. Since plant safety is not degraded by operation with an inoperable primary containment isolation valve, provided the penetration is correctly isolated, it is reasonable to allow the exemp-tion to specification 3.0.4.

The same rationale applies to the secondary containment isolation requirements. In order to ensure that the secondary containment meets its design function, among other things, isolation valves are provided.

With respect to the isolation valves that make up a part of the secon-dary containment boundary, their intended function can be met either by an OPERABLE isolation valve, or a secured (e.g., isolated) isolation valve. Since plant safety is not degraded when an automatic isolation valve is inoperable, but secured in its isolated posi tion per this specification, the question of operational condition changes should be based on other factors.

The Supply System has reviewed this change per 10CFR 50.59 and deter-mined that no unreviewed safety questions will result from this amend-ment. This change has been reviewed and approved by the WNP-2 Plant Operations Committee (POC) and the Supply System Corporate Nuclear Safety Review Board (CNSRB).

The Supply System has reviewed this change per 10CFR50.92 and determined that it does not:

1) Involve a significant increase in the probability or conse-quences of an accident previously evaluated because it merely allows operational mode changes with the primary or secondary containment isolated with an inoperable, but otherwise secured (isolated), isolation valve.

,,2) Create the possibility of a new or different kind of accident from any accident previously evaluated because this change does. not affect or degrade the primary or secondary contain-ment'ntegrity, nor, does it affect other systems important to safety.,

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Involve a significant reduction in the margin of safety because the margin of safety is not affected since this speci-fication continues to provide foi required isolation barriers to be in the isolated condition as required by the design.

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Hr. W. R. Butler Page Three The Supply System has evaluated this request in accordance with the criteria contained in 10CFR 170.21, and has included a warrant for One hundred fifty dollars ($ 150.00) as initial payment for this application for amendment under Facility Category A (Power Reactors).

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

Should you have any questions regarding this matter, please contact Mr.

P. L. Powell, Manager, WNP2 Licensing.

Very truly yours, G.C. Sorensen Manager, Regulatory Programs HLA: kjt Attachments cc: RC Barr BPA JO Bradfute NRC C Eschels EFSEC JB Hartin NRC RV E Revell BPA AD Toth NRC Site NS.Reynolds BLCPSR

StlN fM(3/4.6.3 IEINNICAL SPECIFICATION 5 3/4.6.5)

STATE OF WASHINGTON

Subject:

AMENDMENT 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 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 2 ~ ++748gg., 1985 G. C. So nsen, Manager Regulatory Programs On this day personally appeared before me G. C. Sorensen to me known to be the individual who executed the foregoing instrument and acknowledge that he signed the same as his free act and deed for the uses and purposes therein mentioned.

GIVEN under my hand and seal this ~~ay of , 1985.

Notary Pu c sn and for te State of Washington Residing at

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