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| | issue date = 08/12/1997 | | | issue date = 08/12/1997 |
| | title = Requests Enforcement Discretion from Required Actions Associated W/Ts Action 3.6.1.3.A Which Requires That Penetration Flow Path W/Inoperable Primary Containment Isolation Valve Be Isolated | | | title = Requests Enforcement Discretion from Required Actions Associated W/Ts Action 3.6.1.3.A Which Requires That Penetration Flow Path W/Inoperable Primary Containment Isolation Valve Be Isolated |
| | author name = PARRISH J V | | | author name = Parrish J |
| | author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM | | | author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| | addressee name = | | | addressee name = |
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| =Text= | | =Text= |
| {{#Wiki_filter:CATEGORY 1'REGULAT INFORMATION DISTRIBUTION STEM (RIDS)i~Ni ACCESSION NBR:9708210063 DOC.DATE: 97/08/12 NOTARIZED: | | {{#Wiki_filter:CATEGORY 1 |
| NO DOCKET I FACIL:50-397 | | ~ |
| @PPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME;AUTHOR AFFILIATION PARRISH-,J.V. | | 'REGULAT Ni INFORMATION DISTRIBUTION STEM (RIDS) i ACCESSION NBR:9708210063 DOC.DATE: 97/08/12 NOTARIZED: NO DOCKET I FACIL:50-397 @PPSS 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) |
| Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) | |
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| ==SUBJECT:== | | ==SUBJECT:== |
| Requests enforcement discretion for period of 45 days from TS Action 3.6.1.3.A required to isolate purge line 6,verify penetration flow path isolated every'31 days.DISTRIBUTION CODE: A034D COPIES RECEIVED:LTR ENCL SIZE: TITLE: OR Submittal: | | Requests enforcement discretion for period of 45 days from TS Action 3.6.1.3.A required to isolate purge line 6,verify penetration flow path isolated every '31 days. |
| Containment Purging NOTES: A T E RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL ACRS NRR/DRPM/PECB RES DE RES/DSR/RPSB EXTERNAL: NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME COLBURN,T FILE CENTE R RES/DET/EIB NRC PDR COPIES LTTR ENCL 1 1 1 1 1.1 1 1 1 1 D E NOTE TO ALL"RIDS" RECIPIENTS: | | DISTRIBUTION CODE: A034D COPIES RECEIVED:LTR ENCL SIZE: A TITLE: OR Submittal: Containment Purging T |
| PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL ll j~ | | NOTES: |
| WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~Richland, Washington 99352-0968 August 12, 1997 G02-97-155 Docket No.50-397 Document Control Desk U.S.Nuclear Regulatory Commission Washington, DC 20555 Gentlemen: | | E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD 1 1 COLBURN,T 1 1 INTERNAL ACRS 1 1 FILE CENTE 1 1 NRR/DRPM/PECB 1 1 R 1 .1 RES DE 1 1 RES/DET/EIB 1 1 RES/DSR/RPSB 1 1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D |
| | E NOTE TO ALL "RIDS" RECIPIENTS: |
| | PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL ll |
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| | WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ Richland, Washington 99352-0968 August 12, 1997 G02-97-155 Docket No. 50-397 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen: |
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| ==Subject:== | | ==Subject:== |
| WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR ENFORCEMI<2>IT DISCRETION FROM REQUIRE)ACTIONS OF TECHNICAL SPECIFICATION 3.6.1.3.A | | WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR ENFORCEMI<2>IT DISCRETION FROM REQUIRE) |
| | ACTIONS OF TECHNICALSPECIFICATION 3.6.1.3.A |
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| ==Reference:== | | ==Reference:== |
| | USNRC Administrative Letter 95-05 dated November 7, 1995, "Revisions to Staff Guidance for Implementing NRC Policy on Notices of Enforcement Discretion" The Supply System hereby requests enforcement discretion from the required actions associated ~ |
| | with Technical Specification (TS) Action 3.6.1.3.A. The Supply System has determined that. |
| | traversing in-core probe (TIP) purge line check valve, TIP-V-6, was not verified closed during the, recent refueling outage as required by the Inservice Testing (IST) Program. TS Action 3.6.1.3.A requires that a penetration flow path with an inoperable primary containment isolation valve (PCIV) be isolated. The action specified by TS 3.6.1.3.A has been taken by closing TIP-V-15, thus isolating the purge line penetration to primary containment. |
| | Because of the potential for TIP system degradation with the purge line isolated, the Supply System requests enforcement discretion for a period of 45 days from the TS 3.6.1.3.A required actions to isolate the purge line and verify the penetration flow path isolated every 31 days. During this 45 day period, the Supply System will submit for staff approval an exigent TS Amendment request that would exempt TIP-V-6 from the TS 5.5.6 IST Program requirements to full stroke TIP-V-6 to the closed position each refueling outage. The exigent TS Amendment would be in effect for the duration of the current operating cycle. In addition, the Supply System will verify TIP-V-6 full strokes to the closed position should there be a forced outage of sufficient duration that would allow containment to be deinerted and the test to be performed. The Supply System hereby addresses below each of the 12 criteria identified in the Reference, P 0&) |
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| | 97082i006$ 9708i2 PDR- ADQCK 0500039'7 PDR II!IIII!Illlllllllllllllllllllllllllllll |
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| | REQUEST FOR F<22/FORCEMRPlT DISCRETION FROM REQUIR1H) ACTIONS OF t |
| | TECHNICALSPECIFICATION 3.6.1.3.A The Supply System requests that the required action of TS 3.6.1.3.A.1 and A.2 not be required for TIP-V-6 during a 45 day time period starting with staff approval of this request for enforcement discretion, TIP-V-6 is presently inoperable because a refueling interval IST test requirement to verify the valve full strokes to the closed position was not performed, TS Action 3,6.1.3.A.1 requires that a penetration flow path with an inoperable primary containment isolation valve (PCIV) be isolated "by the use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured." Technical Specification Action 3.6.1.3.A.2 requires the affected penetration flow path be verified isolated every 31 days. The Supply System met the required actions of TS 3.6,1.3.A.1 by closing and deactivating TIP-V-15 to isolate the TIP purge line penetration. |
| | : 2. On July 17, 1997 the IST Program Lead Engineer discovered an error documented in an IST procedure, The procedure is used to exercise TIP-V-6 open and closed as required by the WNP-2 IST Program Plan and is to be performed each refueling outage. The procedure allows credit to be taken for successful completion of a Local Leak Rate Test (LLRT) of the valve if the LLRT is performed during the current refueling outage. In lieu of current LLRT results, the procedure provides discrete steps for verifying valve closure by pressurizing the TIP purge line from a point downstream of the check valve. The Supply System initially concluded that TIP-V-6 was operable but nonconforming using Generic Letter 91-18 guidance. |
| | However, after discussion with the staff on August 12, 1997, the Supply System has determined that LCO 3.6.1.3 must be declared not met. |
| | No LLRT of TIP-V-6 was performed (or required) during this refueling outage (R-12) and the discrete steps for close position verification were not performed. Instead, LLRT results for this valve from the previous refueling outage (R-11) were erroneously used (as indicated by a 1996 test date) and the procedure was incorrectly accepted as complete. |
| | Prompt action is required to permit the TIP purge line penetration to remain unisolated. It is essential to allow the TIP system to remain pressurized to prevent degradation of TIP components and allow axial neutron flux traces of the reactor core. The Nitrogen purge keeps moisture from. entering the TIP indexers and tubing. Moisture can degrade the lubricant used inside the TIP tubing, potentially causing obstructions to TIP probe travel. Obstructions could preclude the use of TIP for the calibration function, ultimately resulting in a plant shutdown. |
| | : 3. Allowing the affected penetration to remain unisolated until an exigent TS Amendment can be approved by the staff does not create a safety concern. Although TIP-V-6 is considered inoperable due to a test not being performed, the valve is still considered to be functional and capable of closing during design basis accident conditions, TIP-V-6 is required to be verified closed every refueling outage based on the refueling outage justification ROJ04 provided in the IST Program Plan. |
| | Review of historical maintenance and test data has shown that this valve had only one LLRT failure, in 1989. Subsequent disassembly found a small amount of debris on the seat of the valve. The valve has passed subsequent leak rate and IST program tests. This valve was |
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| | t REQUEST FOR EAFORCE1VH<JllT DISCRETION FROM REQUIRE& ACTIONS OF t |
| | TECHNICALSPECIFICATION 3.6.1.3.A disassembled as a part of the Check Valve Reliability Program during the 1996 refueling outage and was found to be in excellent condition. Freedom of movement and system cleanliness were verified. |
| | Review of LLRT data for this valve since disassembly in 1989 indicates that valve leakage has been well below the established ASME leakage limit (ASME leakage limit is 74 standard cubic centimeters per minute (sccm); previous test results range from 0 to 23 sccm). The WNP-2 Primary Containment Leakage Rate Test Program developed in accordance with Appendix J, Option B, has provided a leak rate testing interval for TIP-V-6 of five years based on previous valve performance. Based on previous performance the valve can be expected to reliably perform its containment isolation function until the next refueling outage; Since the component reliability assumed in the Probabilistic Safety Assessment (PSA) remains unchanged by this condition, core damage frequency and conditional containment failure probabilities are not affected. |
| | During accident conditions, containment integrity is provided by closure of TIP-V-6. TIP-V-6 has demonstrated reliability through testing and inspection. The outboard primary containment automatic isolation valve, TIP-V-15, provides redundant isolation for this penetration. |
| | : 4. Allowing the affected penetration to remain unisolated for up to 45 days does not represent a situation that is potentially detrimental to the public health and safety. As discussed in item 3 above, TIP-V-6 is expected to close during design basis accident conditions. Primary containment integrity will also be maintained during design basis accident conditions by automatic isolation of TIP-V-15. Based on a review of historical maintenance and test data, allowing the TIP-V-6 penetration to remain unisolated for up to 45 days does not represent an unreviewed safety question nor does it involve a significant hazards consideration per the criteria of 10 CFR 50.92 |
| | : 5. Allowing the affected penetration to remain unisolated for up to 45 days will not have an adverse impact on the environment. Based on a review of historical maintenance and test data, TIP-V-6 is expected to function as designed to isolate the affected penetration. Therefore, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. Additionally, there is no significant increase in individual or cumulative occupational radiation exposure. |
| | : 6. There are no compensatory measures proposed. Historical valve performance reflects a high degree of component reliability, and as such, no compensatory measures are necessary. |
| | : 7. It is requested that enforcement discretion for non-compliance with TS Action 3.6.1.3.A be in effect for 45 days to allow time for processing of an exigent TS Amendment request. Past testing and inspection demonstrates the functional condition of the valve, and provides reasonable assurance of performance. |
| | : 8. The requested enforcement discretion has been approved by the Plant Operations Committee. |
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| USNRC Administrative Letter 95-05 dated November 7, 1995,"Revisions to Staff Guidance for Implementing NRC Policy on Notices of Enforcement Discretion" The Supply System hereby requests enforcement discretion from the required actions associated
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| ~with Technical Specification (TS)Action 3.6.1.3.A. | | , ~ |
| The Supply System has determined that.traversing in-core probe (TIP)purge line check valve, TIP-V-6, was not verified closed during the, recent refueling outage as required by the Inservice Testing (IST)Program.TS Action 3.6.1.3.A requires that a penetration flow path with an inoperable primary containment isolation valve (PCIV)be isolated.The action specified by TS 3.6.1.3.A has been taken by closing TIP-V-15, thus isolating the purge line penetration to primary containment.
| | ~ t REQUEST FOR ENFORCEMENT DISCRETION FROM REQUIRED ACTIONS OF t |
| Because of the potential for TIP system degradation with the purge line isolated, the Supply System requests enforcement discretion for a period of 45 days from the TS 3.6.1.3.A required actions to isolate the purge line and verify the penetration flow path isolated every 31 days.During this 45 day period, the Supply System will submit for staff approval an exigent TS Amendment request that would exempt TIP-V-6 from the TS 5.5.6 IST Program requirements to full stroke TIP-V-6 to the closed position each refueling outage.The exigent TS Amendment would be in effect for the duration of the current operating cycle.In addition, the Supply System will verify TIP-V-6 full strokes to the closed position should there be a forced outage of sufficient duration that would allow containment to be deinerted and the test to be performed.
| | TECHNICALSPECIFICATION 3.6.1.3.A |
| The Supply System hereby addresses below each of the 12 criteria identified in the Reference, 97082i006$
| | : 9. This requested enforcement discretion meets criterion 1(a) of section B of Part 9900. |
| 9708i2 PDR-ADQCK 0500039'7 P.'" PDR P 0&)II!IIII!Illlllllllllllllllllllllllllllll I f/'
| | Enforcement discretion is required to avoid the transient associated with a forced plant shutdown which would result from long term isolation of the TIP penetration. The Supply System considers repetitive opening of TIP-V-15 under administrative controls, as permitted by TS 3.6.1.3, to be undesirable. |
| t t Page 2 REQUEST FOR F<22/FORCEMRPlT DISCRETION FROM REQUIR1H)ACTIONS OF TECHNICAL SPECIFICATION 3.6.1.3.A The Supply System requests that the required action of TS 3.6.1.3.A.1 and A.2 not be required for TIP-V-6 during a 45 day time period starting with staff approval of this request for enforcement discretion, TIP-V-6 is presently inoperable because a refueling interval IST test requirement to verify the valve full strokes to the closed position was not performed, TS Action 3,6.1.3.A.1 requires that a penetration flow path with an inoperable primary containment isolation valve (PCIV)be isolated"by the use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured." Technical Specification Action 3.6.1.3.A.2 requires the affected penetration flow path be verified isolated every 31 days.The Supply System met the required actions of TS 3.6,1.3.A.1 by closing and deactivating TIP-V-15 to isolate the TIP purge line penetration.
| | : 10. An exigent TS Amendment request. will be submitted to the staff within 48 hours. Attached is marked-up page 5.0-11 showing the proposed change. |
| 2.On July 17, 1997 the IST Program Lead Engineer discovered an error documented in an IST procedure, The procedure is used to exercise TIP-V-6 open and closed as required by the WNP-2 IST Program Plan and is to be performed each refueling outage.The procedure allows credit to be taken for successful completion of a Local Leak Rate Test (LLRT)of the valve if the LLRT is performed during the current refueling outage.In lieu of current LLRT results, the procedure provides discrete steps for verifying valve closure by pressurizing the TIP purge line from a point downstream of the check valve.The Supply System initially concluded that TIP-V-6 was operable but nonconforming using Generic Letter 91-18 guidance.However, after discussion with the staff on August 12, 1997, the Supply System has determined that LCO 3.6.1.3 must be declared not met.No LLRT of TIP-V-6 was performed (or required)during this refueling outage (R-12)and the discrete steps for close position verification were not performed.
| | : 11. Adoption of "Improved" Technical Specifications at WNP-2 has not eliminated the need for this request for enforcement discretion. |
| Instead, LLRT results for this valve from the previous refueling outage (R-11)were erroneously used (as indicated by a 1996 test date)and the procedure was incorrectly accepted as complete.Prompt action is required to permit the TIP purge line penetration to remain unisolated.
| | : 12. The Supply System knows of no additional information that willbe needed by the staff. |
| It is essential to allow the TIP system to remain pressurized to prevent degradation of TIP components and allow axial neutron flux traces of the reactor core.The Nitrogen purge keeps moisture from.entering the TIP indexers and tubing.Moisture can degrade the lubricant used inside the TIP tubing, potentially causing obstructions to TIP probe travel.Obstructions could preclude the use of TIP for the calibration function, ultimately resulting in a plant shutdown.3.Allowing the affected penetration to remain unisolated until an exigent TS Amendment can be approved by the staff does not create a safety concern.Although TIP-V-6 is considered inoperable due to a test not being performed, the valve is still considered to be functional and capable of closing during design basis accident conditions, TIP-V-6 is required to be verified closed every refueling outage based on the refueling outage justification ROJ04 provided in the IST Program Plan.Review of historical maintenance and test data has shown that this valve had only one LLRT failure, in 1989.Subsequent disassembly found a small amount of debris on the seat of the valve.The valve has passed subsequent leak rate and IST program tests.This valve was U+tl'II t+Q 4 444-1 1' t t REQUEST FOR EAFORCE1VH<JllT DISCRETION FROM REQUIRE&ACTIONS OF TECHNICAL SPECIFICATION 3.6.1.3.A disassembled as a part of the Check Valve Reliability Program during the 1996 refueling outage and was found to be in excellent condition.
| | Should you have any questions or desire additional information regarding this matter, please contact P. J. Inserra at (509) 377-4147. |
| Freedom of movement and system cleanliness were verified.Review of LLRT data for this valve since disassembly in 1989 indicates that valve leakage has been well below the established ASME leakage limit (ASME leakage limit is 74 standard cubic centimeters per minute (sccm);previous test results range from 0 to 23 sccm).The WNP-2 Primary Containment Leakage Rate Test Program developed in accordance with Appendix J, Option B, has provided a leak rate testing interval for TIP-V-6 of five years based on previous valve performance.
| | Respectfully, J.V. Parrish |
| Based on previous performance the valve can be expected to reliably perform its containment isolation function until the next refueling outage;Since the component reliability assumed in the Probabilistic Safety Assessment (PSA)remains unchanged by this condition, core damage frequency and conditional containment failure probabilities are not affected.During accident conditions, containment integrity is provided by closure of TIP-V-6.TIP-V-6 has demonstrated reliability through testing and inspection.
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| The outboard primary containment automatic isolation valve, TIP-V-15, provides redundant isolation for this penetration.
| | Chief Executive Officer Mail Drop 1023 Attachment EW Merschoff - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office TG Colburn - NRR NRC Sr. Resident Inspector - 927N DL Williams - BPA/399 PD Robinson - Winston & Strawn}} |
| 4.Allowing the affected penetration to remain unisolated for up to 45 days does not represent a situation that is potentially detrimental to the public health and safety.As discussed in item 3 above, TIP-V-6 is expected to close during design basis accident conditions.
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| Primary containment integrity will also be maintained during design basis accident conditions by automatic isolation of TIP-V-15.Based on a review of historical maintenance and test data, allowing the TIP-V-6 penetration to remain unisolated for up to 45 days does not represent an unreviewed safety question nor does it involve a significant hazards consideration per the criteria of 10 CFR 50.92 5.Allowing the affected penetration to remain unisolated for up to 45 days will not have an adverse impact on the environment.
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| Based on a review of historical maintenance and test data, TIP-V-6 is expected to function as designed to isolate the affected penetration.
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| Therefore, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.Additionally, there is no significant increase in individual or cumulative occupational radiation exposure.6.There are no compensatory measures proposed.Historical valve performance reflects a high degree of component reliability, and as such, no compensatory measures are necessary.
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| 7.It is requested that enforcement discretion for non-compliance with TS Action 3.6.1.3.A be in effect for 45 days to allow time for processing of an exigent TS Amendment request.Past testing and inspection demonstrates the functional condition of the valve, and provides reasonable assurance of performance.
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| 8.The requested enforcement discretion has been approved by the Plant Operations Committee.
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| ,~~j~t t REQUEST FOR ENFORCEMENT DISCRETION FROM REQUIRED ACTIONS OF TECHNICAL SPECIFICATION 3.6.1.3.A 9.This requested enforcement discretion meets criterion 1(a)of section B of Part 9900.Enforcement discretion is required to avoid the transient associated with a forced plant shutdown which would result from long term isolation of the TIP penetration.
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| The Supply System considers repetitive opening of TIP-V-15 under administrative controls, as permitted by TS 3.6.1.3, to be undesirable. | |
| 10.An exigent TS Amendment request.will be submitted to the staff within 48 hours.Attached is marked-up page 5.0-11 showing the proposed change.11.Adoption of"Improved" Technical Specifications at WNP-2 has not eliminated the need for this request for enforcement discretion. | |
| 12.The Supply System knows of no additional information that will be needed by the staff.Should you have any questions or desire additional information regarding this matter, please contact P.J.Inserra at (509)377-4147.Respectfully,~~J.V.Parrish Chief Executive Officer Mail Drop 1023 Attachment EW Merschoff-NRC RIV KE Perkins, Jr.-NRC RIV, Walnut Creek Field Office TG Colburn-NRR NRC Sr.Resident Inspector-927N DL Williams-BPA/399 PD Robinson-Winston&Strawn}} | |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K9681999-10-19019 October 1999 Ack Receipt of Transmitting Rev 40 to Physical Security Plan for Washington Nuclear Plant 2.Based on Determination That Changes Do Not Decrease Effectiveness of Plan,No NRC Approval Required ML17284A8981999-10-14014 October 1999 Forwards Rev 0 to WNP-2 Cycle 15,COLR 99-15, IAW Requirements of TS 5.6.5 ML17284A9061999-09-24024 September 1999 Forwards Final Rept for 990812 out-of-sequence Drills for Energy Northwest Washington Nuclear Power Project 2 (Lab, Food Control Point & Milk Sampling).No Deficiences & No Areas Requiring C/A Identified in Three Drills ML17284A8881999-09-24024 September 1999 Informs NRC of Change in Schedule Pertaining to Final Implementation of Reactor Stability long-term Solution for WNP-2 ML17292B7591999-09-24024 September 1999 Forwards Rev 24 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b), 50.54(q) & 10CFR50 App E.Detailed Synopsis of Changes,Encl ML17292B7581999-09-22022 September 1999 Forwards NRC Forms 396 & 398 for Nl Hancock,License SOP-50027-3,AR Herrington,License OP-50013-3,WH Sawyer, License SOP-50023-3 & Dl Strote,License SOP-50031-3,for Renewal of Licenses.Without NRC Forms 396 & 398 ML17284A8811999-09-0909 September 1999 Forwards Response to NRC 990623 RAI to Support Review of Pending Request for Amend to Reactor pressure-temp Limit Curve TS GO2-99-168, Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3)1999-09-0808 September 1999 Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3) ML17284A8711999-08-30030 August 1999 Informs Staff of Errors in world-wide-web Database Related to WNP-2 Reactor Vessel Structural integrity.Marked-up Pages Containing Errors or Omissions Will Be Forwarded by 991201 ML17284A8751999-08-30030 August 1999 Provides Correct Page from License NPF-21 Marked to Show Rev Addressed in 990729 Application for Amend,Which Included Page That Was Inadvertently Included as Attachment 4.Replace Attachment 4 with Attached Page & Disregard Attachment 5 ML17284A8721999-08-30030 August 1999 Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld ML17292B7531999-08-24024 August 1999 Requests That Eleven Individuals Listed Below Take BWR Generic Fundamentals Examination to Be Administered on 991006 ML17292B7511999-08-24024 August 1999 Forwards Fitness for Duty (FFD) Semiannual Performance Data Rept for Jan-June 1999,per 10CFR26.71(d) ML17284A8701999-08-19019 August 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee & NRC Form 398, Personal Qualification Statement - Licensee, for Jd Prescott (License SOP-50262-1).Without Encls ML17292B7501999-08-19019 August 1999 Informs Staff That Licensee Has Completed Review of NRC SER for B&Wog Util Resolution Guidance Document Addressing ECCS Suction Strainer Blockage ML17284A8681999-08-12012 August 1999 Submits Two ISI Program Plan Relief Requests for NRC Review & Approval,Per 10CFR50.55a(a)(3)(i).Proposed Alternatives Provide Acceptable Level of Quality & Safety ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML17284A8541999-08-0202 August 1999 Forwards Proprietary Addl Info to Support Review of Pending Request for Amend to MCPR Safety Limit Ts.Info Consists of Proprietary Ltr from Abb Combustion Engineering,Inc.Encl Withheld ML17284A8531999-07-30030 July 1999 Forwards Estimate of Number of Licensing Action Requests Planned for Submittal in Future,As Requested in Administrative Ltr 99-02.Twenty-nine Submittals Scheduled for Fy 2000 & Four for Fy 2001 ML17284A8301999-07-22022 July 1999 Clarifies Change of Licensee Name from Wpps to Energy Northwest & Change of Facility Name from Wppss Nuclear Project Number 2 to WNP-2,as Requested in 990719 Telcon with Js Cushing of NRC.Marked-up OL Pages,Encl ML17292B7451999-07-20020 July 1999 Forwards Rev 23 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b) & 50.54(q) & 10CFR50 App E.Rev 23 Provides Updated Description Re Establishment of Separate Emergency Operation Centers for Benton & Franklin Counties ML17292B7391999-07-16016 July 1999 Submits Withdrawal of Request for Amend to Secondary Containment & Standby Gas Treatment Sys Ts.Util Currently Plan to re-submit Amend Request in Entirety by 991112 ML17292B7381999-07-12012 July 1999 Forwards NRC Form 396 & NRC Form 398,for If Sumsion,License OP-50487 & Ga Westergard,License SOP-50415 for Renewal of Operator Licenses.Without Encls ML17292B7171999-07-0606 July 1999 Provides Notification of Early Completion on 990630 of Exception Noted in 990629 Ltr.Equipment within Scope of GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants, Evaluated & Y2K Ready ML17292B7181999-07-0202 July 1999 Responds to 990623 RAI to Support Review of Evaluation of Planar Indication Found on Weld Number 24RRC(2)A-1 During 1998 RO ML17292B7161999-06-30030 June 1999 Forwards Addl Info Requested in 990513 Ltr to Support Review of Pending Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML17292B7131999-06-29029 June 1999 Forwards Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. ML17292B7091999-06-21021 June 1999 Forwards Proprietary Response to NRC 990603 RAI Re Licensee Request for Amend to MCPR Safety Limit Tss.Proprietary Info Withheld IAW Requirements of 10CFR2.790 ML17292B7041999-06-17017 June 1999 Forwards NRC Forms 396 & 398 for Three Individuals Listed Below for Renewal of Operator Licenses.Without Encls ML17292B7031999-06-10010 June 1999 Forwards Response to NRC 990511 RAI Re License Request for Amend to Secondary Containment & SGTS Tss.Results of Addl Benchmark of Gothic Computer Code Performed to Demonstrate Modeling Capability of Drawdown Response,Encl ML17292B6841999-06-0404 June 1999 Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs ML17292B6851999-06-0101 June 1999 Forwards 1999 Quality Audit of WNP-2 Emergency Preparedness Program, Per NUREG-0654,Section Ii,Criteria P.9.Seven Problem Evaluation Requests & Nine Recommendations for Improvement Were Issued as Result of Audit Activities ML17292B6831999-05-25025 May 1999 Informs That Request for NRC Approval of Changes to Emergency Plan Requesting Reduction in on-shift HP Staffing, Is Retracted.Util Will Resubmit Request with Required Addl Info at Later Date ML17292B6751999-05-25025 May 1999 Forwards Proprietary ABB-CE Ltr Re WNP-2 Cycle 15 SLMCPR & Core Reload Design Rept,Per Util Request for Amend Re MCPR Safety Limits.Proprietary Info Withheld,Per 10CFR2.790 ML20206U4501999-05-19019 May 1999 Ack Receipt of Which Transmitted Rev 39 to Physical Security Plan,Per 10CFR50.54(p).No NRC Approval Is Required,Since Changes Do Not Decrease Effectiveness of Security Plan ML17292B6661999-05-0707 May 1999 Requests Exemption to Requirement in 10CFR55.59(a)(2) Re Annual Operating Test requirements.One-time Exemption from Requirement to Period Not to Exceed 15-months from Last Date of Passing Operating Exam for Licensee at Facility ML17292B6531999-05-0303 May 1999 Forwards Response to NRC 990402 RAI Re Licensed Operator Positive Drug Test.Encl Withheld,Per 10CFR2.790 ML17292B6561999-04-29029 April 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Safe End & Calculation Mod Record CMR-98-0243, Fracture Mechanics Evaluation of N1A Nozzle Safe End, as Suppl Info to ISI Exam ML17292B6421999-04-19019 April 1999 Responds to NRC 990319 Ltr Re Violations Noted in Insp Rept 50-397/99-01.Corrective Actions:Provisions Are Presently in Place to Maintain Adequate Level of Security GO2-99-073, Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.7901999-04-19019 April 1999 Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.790 ML17292B6401999-04-13013 April 1999 Requests That WNP-2 Operator Requalification Program Be Granted one-time Extension Beyond Requirement in 10CFR55.59(a)(2) for Annual Operating Tests ML17292B6371999-04-12012 April 1999 Forwards Response to NRC 990211 RAI Re Util Request for Amend to Secondary Containment & SBGTS TS ML17292B6281999-04-0606 April 1999 Informs NRC That Insp Interval Ending Date for ISI Program Plan Has Been Extended by One Year to Dec 12,2005 Due to Changes in Plant Refueling Outage Schedule ML20196K6961999-03-30030 March 1999 Ack Receipt of ,Transmitting Rev 38 to Physical Security Plan for Plant.No NRC Approval Is Required,In Accordance with 10CFR50.54(p) GO2-99-060, Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1)1999-03-26026 March 1999 Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1) ML17292B6131999-03-24024 March 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Nozzle Safe End. Info Will Be Used to Assist NRC in Review of WNP-2 ISI Activities Associated with Evaluation of Planar Indication ML20204F0261999-03-19019 March 1999 Forwards Insp Rept 50-397/99-01 on 990201-04 & 0303-05.No Violations Noted.Areas of Physical Security Plan Effectively Implemented with Listed Exceptions ML17292B6001999-03-16016 March 1999 Responds to Weakness Noted in Insp Rept 50-397/98-24. Corrective Actions:Developed Document to Identify Areas Needing Improvement,Assigned Responsibility for Actions & Provided Milestones for Achievement ML17292B5941999-03-16016 March 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, & NRC Form 398, Personal Qualification Statement - Licensee, for MD Comstock,Mc Naulty & RR Nelson.Without Encls 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17284A8981999-10-14014 October 1999 Forwards Rev 0 to WNP-2 Cycle 15,COLR 99-15, IAW Requirements of TS 5.6.5 ML17284A9061999-09-24024 September 1999 Forwards Final Rept for 990812 out-of-sequence Drills for Energy Northwest Washington Nuclear Power Project 2 (Lab, Food Control Point & Milk Sampling).No Deficiences & No Areas Requiring C/A Identified in Three Drills ML17292B7591999-09-24024 September 1999 Forwards Rev 24 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b), 50.54(q) & 10CFR50 App E.Detailed Synopsis of Changes,Encl ML17284A8881999-09-24024 September 1999 Informs NRC of Change in Schedule Pertaining to Final Implementation of Reactor Stability long-term Solution for WNP-2 ML17292B7581999-09-22022 September 1999 Forwards NRC Forms 396 & 398 for Nl Hancock,License SOP-50027-3,AR Herrington,License OP-50013-3,WH Sawyer, License SOP-50023-3 & Dl Strote,License SOP-50031-3,for Renewal of Licenses.Without NRC Forms 396 & 398 ML17284A8811999-09-0909 September 1999 Forwards Response to NRC 990623 RAI to Support Review of Pending Request for Amend to Reactor pressure-temp Limit Curve TS GO2-99-168, Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3)1999-09-0808 September 1999 Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3) ML17284A8751999-08-30030 August 1999 Provides Correct Page from License NPF-21 Marked to Show Rev Addressed in 990729 Application for Amend,Which Included Page That Was Inadvertently Included as Attachment 4.Replace Attachment 4 with Attached Page & Disregard Attachment 5 ML17284A8721999-08-30030 August 1999 Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld ML17284A8711999-08-30030 August 1999 Informs Staff of Errors in world-wide-web Database Related to WNP-2 Reactor Vessel Structural integrity.Marked-up Pages Containing Errors or Omissions Will Be Forwarded by 991201 ML17292B7531999-08-24024 August 1999 Requests That Eleven Individuals Listed Below Take BWR Generic Fundamentals Examination to Be Administered on 991006 ML17292B7511999-08-24024 August 1999 Forwards Fitness for Duty (FFD) Semiannual Performance Data Rept for Jan-June 1999,per 10CFR26.71(d) ML17284A8701999-08-19019 August 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee & NRC Form 398, Personal Qualification Statement - Licensee, for Jd Prescott (License SOP-50262-1).Without Encls ML17292B7501999-08-19019 August 1999 Informs Staff That Licensee Has Completed Review of NRC SER for B&Wog Util Resolution Guidance Document Addressing ECCS Suction Strainer Blockage ML17284A8681999-08-12012 August 1999 Submits Two ISI Program Plan Relief Requests for NRC Review & Approval,Per 10CFR50.55a(a)(3)(i).Proposed Alternatives Provide Acceptable Level of Quality & Safety ML17284A8541999-08-0202 August 1999 Forwards Proprietary Addl Info to Support Review of Pending Request for Amend to MCPR Safety Limit Ts.Info Consists of Proprietary Ltr from Abb Combustion Engineering,Inc.Encl Withheld ML17284A8531999-07-30030 July 1999 Forwards Estimate of Number of Licensing Action Requests Planned for Submittal in Future,As Requested in Administrative Ltr 99-02.Twenty-nine Submittals Scheduled for Fy 2000 & Four for Fy 2001 ML17284A8301999-07-22022 July 1999 Clarifies Change of Licensee Name from Wpps to Energy Northwest & Change of Facility Name from Wppss Nuclear Project Number 2 to WNP-2,as Requested in 990719 Telcon with Js Cushing of NRC.Marked-up OL Pages,Encl ML17292B7451999-07-20020 July 1999 Forwards Rev 23 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b) & 50.54(q) & 10CFR50 App E.Rev 23 Provides Updated Description Re Establishment of Separate Emergency Operation Centers for Benton & Franklin Counties ML17292B7391999-07-16016 July 1999 Submits Withdrawal of Request for Amend to Secondary Containment & Standby Gas Treatment Sys Ts.Util Currently Plan to re-submit Amend Request in Entirety by 991112 ML17292B7381999-07-12012 July 1999 Forwards NRC Form 396 & NRC Form 398,for If Sumsion,License OP-50487 & Ga Westergard,License SOP-50415 for Renewal of Operator Licenses.Without Encls ML17292B7171999-07-0606 July 1999 Provides Notification of Early Completion on 990630 of Exception Noted in 990629 Ltr.Equipment within Scope of GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants, Evaluated & Y2K Ready ML17292B7181999-07-0202 July 1999 Responds to 990623 RAI to Support Review of Evaluation of Planar Indication Found on Weld Number 24RRC(2)A-1 During 1998 RO ML17292B7161999-06-30030 June 1999 Forwards Addl Info Requested in 990513 Ltr to Support Review of Pending Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML17292B7131999-06-29029 June 1999 Forwards Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. ML17292B7091999-06-21021 June 1999 Forwards Proprietary Response to NRC 990603 RAI Re Licensee Request for Amend to MCPR Safety Limit Tss.Proprietary Info Withheld IAW Requirements of 10CFR2.790 ML17292B7041999-06-17017 June 1999 Forwards NRC Forms 396 & 398 for Three Individuals Listed Below for Renewal of Operator Licenses.Without Encls ML17292B7031999-06-10010 June 1999 Forwards Response to NRC 990511 RAI Re License Request for Amend to Secondary Containment & SGTS Tss.Results of Addl Benchmark of Gothic Computer Code Performed to Demonstrate Modeling Capability of Drawdown Response,Encl ML17292B6841999-06-0404 June 1999 Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs ML17292B6851999-06-0101 June 1999 Forwards 1999 Quality Audit of WNP-2 Emergency Preparedness Program, Per NUREG-0654,Section Ii,Criteria P.9.Seven Problem Evaluation Requests & Nine Recommendations for Improvement Were Issued as Result of Audit Activities ML17292B6751999-05-25025 May 1999 Forwards Proprietary ABB-CE Ltr Re WNP-2 Cycle 15 SLMCPR & Core Reload Design Rept,Per Util Request for Amend Re MCPR Safety Limits.Proprietary Info Withheld,Per 10CFR2.790 ML17292B6831999-05-25025 May 1999 Informs That Request for NRC Approval of Changes to Emergency Plan Requesting Reduction in on-shift HP Staffing, Is Retracted.Util Will Resubmit Request with Required Addl Info at Later Date ML17292B6661999-05-0707 May 1999 Requests Exemption to Requirement in 10CFR55.59(a)(2) Re Annual Operating Test requirements.One-time Exemption from Requirement to Period Not to Exceed 15-months from Last Date of Passing Operating Exam for Licensee at Facility ML17292B6531999-05-0303 May 1999 Forwards Response to NRC 990402 RAI Re Licensed Operator Positive Drug Test.Encl Withheld,Per 10CFR2.790 ML17292B6561999-04-29029 April 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Safe End & Calculation Mod Record CMR-98-0243, Fracture Mechanics Evaluation of N1A Nozzle Safe End, as Suppl Info to ISI Exam ML17292B6421999-04-19019 April 1999 Responds to NRC 990319 Ltr Re Violations Noted in Insp Rept 50-397/99-01.Corrective Actions:Provisions Are Presently in Place to Maintain Adequate Level of Security GO2-99-073, Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.7901999-04-19019 April 1999 Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.790 ML17292B6401999-04-13013 April 1999 Requests That WNP-2 Operator Requalification Program Be Granted one-time Extension Beyond Requirement in 10CFR55.59(a)(2) for Annual Operating Tests ML17292B6371999-04-12012 April 1999 Forwards Response to NRC 990211 RAI Re Util Request for Amend to Secondary Containment & SBGTS TS ML17292B6281999-04-0606 April 1999 Informs NRC That Insp Interval Ending Date for ISI Program Plan Has Been Extended by One Year to Dec 12,2005 Due to Changes in Plant Refueling Outage Schedule GO2-99-060, Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1)1999-03-26026 March 1999 Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1) ML17292B6131999-03-24024 March 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Nozzle Safe End. Info Will Be Used to Assist NRC in Review of WNP-2 ISI Activities Associated with Evaluation of Planar Indication ML17292B5991999-03-16016 March 1999 Informs That Listed Property & Liability Insurance Coverage for WNP-2 Is in Force,In Compliance with Licensing Responsibilities Delineated in 10CFR50.54(w)(3) ML17292B5911999-03-16016 March 1999 Forwards 1998 Environ Operating Rept, Per Reporting Requirements of Section 5.4.1 of WNP-2 Epp.No Design or Operational Changes or Tests in 1998 Involved Unreviewed Environ Question ML17292B5941999-03-16016 March 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, & NRC Form 398, Personal Qualification Statement - Licensee, for MD Comstock,Mc Naulty & RR Nelson.Without Encls ML17292B6001999-03-16016 March 1999 Responds to Weakness Noted in Insp Rept 50-397/98-24. Corrective Actions:Developed Document to Identify Areas Needing Improvement,Assigned Responsibility for Actions & Provided Milestones for Achievement ML17292B5901999-03-11011 March 1999 Forwards Hard Copy of Addl Occupational Exposure Data Requested in GL 94-04,per 990303 e-mail.Original Electronic Version Was Corrupted ML17292B5681999-03-0101 March 1999 Forwards Radioactive Effluent Release Rept for 1998, IAW 10CFR50.36a(a)(2) & TS 5.6.3 & Complete Copy of WNP-2 ODCM Per TS 5.5.1 ML17292B5651999-02-22022 February 1999 Forwards Relief Request 2ISI-20,proposing Alternate Exam Expected to Reduce Dose Significantly & Still Provide Adequate Safety & Quality.Attached Relief Request Will Be Used to Support ALARA Dose Reduction Efforts During Maint ML17292B5581999-02-0404 February 1999 Requests Change to Co Which Modified WNP-2 OL to Reflect Schedule for Implementing Thermo-Lag 330-1 Fire Barrier C/As.Change Requested to Reflect That Final Implementation of C/As Will Be Completed During Fall 1999 Not Spring 1999 1999-09-09
[Table view] |
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CATEGORY 1
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'REGULAT Ni INFORMATION DISTRIBUTION STEM (RIDS) i ACCESSION NBR:9708210063 DOC.DATE: 97/08/12 NOTARIZED: NO DOCKET I FACIL:50-397 @PPSS 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:
Requests enforcement discretion for period of 45 days from TS Action 3.6.1.3.A required to isolate purge line 6,verify penetration flow path isolated every '31 days.
DISTRIBUTION CODE: A034D COPIES RECEIVED:LTR ENCL SIZE: A TITLE: OR Submittal: Containment Purging T
NOTES:
E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD 1 1 COLBURN,T 1 1 INTERNAL ACRS 1 1 FILE CENTE 1 1 NRR/DRPM/PECB 1 1 R 1 .1 RES DE 1 1 RES/DET/EIB 1 1 RES/DSR/RPSB 1 1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D
E NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL ll
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ Richland, Washington 99352-0968 August 12, 1997 G02-97-155 Docket No. 50-397 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:
Subject:
WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR ENFORCEMI<2>IT DISCRETION FROM REQUIRE)
ACTIONS OF TECHNICALSPECIFICATION 3.6.1.3.A
Reference:
USNRC Administrative Letter 95-05 dated November 7, 1995, "Revisions to Staff Guidance for Implementing NRC Policy on Notices of Enforcement Discretion" The Supply System hereby requests enforcement discretion from the required actions associated ~
with Technical Specification (TS) Action 3.6.1.3.A. The Supply System has determined that.
traversing in-core probe (TIP) purge line check valve, TIP-V-6, was not verified closed during the, recent refueling outage as required by the Inservice Testing (IST) Program. TS Action 3.6.1.3.A requires that a penetration flow path with an inoperable primary containment isolation valve (PCIV) be isolated. The action specified by TS 3.6.1.3.A has been taken by closing TIP-V-15, thus isolating the purge line penetration to primary containment.
Because of the potential for TIP system degradation with the purge line isolated, the Supply System requests enforcement discretion for a period of 45 days from the TS 3.6.1.3.A required actions to isolate the purge line and verify the penetration flow path isolated every 31 days. During this 45 day period, the Supply System will submit for staff approval an exigent TS Amendment request that would exempt TIP-V-6 from the TS 5.5.6 IST Program requirements to full stroke TIP-V-6 to the closed position each refueling outage. The exigent TS Amendment would be in effect for the duration of the current operating cycle. In addition, the Supply System will verify TIP-V-6 full strokes to the closed position should there be a forced outage of sufficient duration that would allow containment to be deinerted and the test to be performed. The Supply System hereby addresses below each of the 12 criteria identified in the Reference, P 0&)
P .
97082i006$ 9708i2 PDR- ADQCK 0500039'7 PDR II!IIII!Illlllllllllllllllllllllllllllll
I f/'
Page 2 t
REQUEST FOR F<22/FORCEMRPlT DISCRETION FROM REQUIR1H) ACTIONS OF t
TECHNICALSPECIFICATION 3.6.1.3.A The Supply System requests that the required action of TS 3.6.1.3.A.1 and A.2 not be required for TIP-V-6 during a 45 day time period starting with staff approval of this request for enforcement discretion, TIP-V-6 is presently inoperable because a refueling interval IST test requirement to verify the valve full strokes to the closed position was not performed, TS Action 3,6.1.3.A.1 requires that a penetration flow path with an inoperable primary containment isolation valve (PCIV) be isolated "by the use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured." Technical Specification Action 3.6.1.3.A.2 requires the affected penetration flow path be verified isolated every 31 days. The Supply System met the required actions of TS 3.6,1.3.A.1 by closing and deactivating TIP-V-15 to isolate the TIP purge line penetration.
- 2. On July 17, 1997 the IST Program Lead Engineer discovered an error documented in an IST procedure, The procedure is used to exercise TIP-V-6 open and closed as required by the WNP-2 IST Program Plan and is to be performed each refueling outage. The procedure allows credit to be taken for successful completion of a Local Leak Rate Test (LLRT) of the valve if the LLRT is performed during the current refueling outage. In lieu of current LLRT results, the procedure provides discrete steps for verifying valve closure by pressurizing the TIP purge line from a point downstream of the check valve. The Supply System initially concluded that TIP-V-6 was operable but nonconforming using Generic Letter 91-18 guidance.
However, after discussion with the staff on August 12, 1997, the Supply System has determined that LCO 3.6.1.3 must be declared not met.
No LLRT of TIP-V-6 was performed (or required) during this refueling outage (R-12) and the discrete steps for close position verification were not performed. Instead, LLRT results for this valve from the previous refueling outage (R-11) were erroneously used (as indicated by a 1996 test date) and the procedure was incorrectly accepted as complete.
Prompt action is required to permit the TIP purge line penetration to remain unisolated. It is essential to allow the TIP system to remain pressurized to prevent degradation of TIP components and allow axial neutron flux traces of the reactor core. The Nitrogen purge keeps moisture from. entering the TIP indexers and tubing. Moisture can degrade the lubricant used inside the TIP tubing, potentially causing obstructions to TIP probe travel. Obstructions could preclude the use of TIP for the calibration function, ultimately resulting in a plant shutdown.
- 3. Allowing the affected penetration to remain unisolated until an exigent TS Amendment can be approved by the staff does not create a safety concern. Although TIP-V-6 is considered inoperable due to a test not being performed, the valve is still considered to be functional and capable of closing during design basis accident conditions, TIP-V-6 is required to be verified closed every refueling outage based on the refueling outage justification ROJ04 provided in the IST Program Plan.
Review of historical maintenance and test data has shown that this valve had only one LLRT failure, in 1989. Subsequent disassembly found a small amount of debris on the seat of the valve. The valve has passed subsequent leak rate and IST program tests. This valve was
U
+tl II t+ Q 4
444-1 1'
t REQUEST FOR EAFORCE1VH<JllT DISCRETION FROM REQUIRE& ACTIONS OF t
TECHNICALSPECIFICATION 3.6.1.3.A disassembled as a part of the Check Valve Reliability Program during the 1996 refueling outage and was found to be in excellent condition. Freedom of movement and system cleanliness were verified.
Review of LLRT data for this valve since disassembly in 1989 indicates that valve leakage has been well below the established ASME leakage limit (ASME leakage limit is 74 standard cubic centimeters per minute (sccm); previous test results range from 0 to 23 sccm). The WNP-2 Primary Containment Leakage Rate Test Program developed in accordance with Appendix J, Option B, has provided a leak rate testing interval for TIP-V-6 of five years based on previous valve performance. Based on previous performance the valve can be expected to reliably perform its containment isolation function until the next refueling outage; Since the component reliability assumed in the Probabilistic Safety Assessment (PSA) remains unchanged by this condition, core damage frequency and conditional containment failure probabilities are not affected.
During accident conditions, containment integrity is provided by closure of TIP-V-6. TIP-V-6 has demonstrated reliability through testing and inspection. The outboard primary containment automatic isolation valve, TIP-V-15, provides redundant isolation for this penetration.
- 4. Allowing the affected penetration to remain unisolated for up to 45 days does not represent a situation that is potentially detrimental to the public health and safety. As discussed in item 3 above, TIP-V-6 is expected to close during design basis accident conditions. Primary containment integrity will also be maintained during design basis accident conditions by automatic isolation of TIP-V-15. Based on a review of historical maintenance and test data, allowing the TIP-V-6 penetration to remain unisolated for up to 45 days does not represent an unreviewed safety question nor does it involve a significant hazards consideration per the criteria of 10 CFR 50.92
- 5. Allowing the affected penetration to remain unisolated for up to 45 days will not have an adverse impact on the environment. Based on a review of historical maintenance and test data, TIP-V-6 is expected to function as designed to isolate the affected penetration. Therefore, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. Additionally, there is no significant increase in individual or cumulative occupational radiation exposure.
- 6. There are no compensatory measures proposed. Historical valve performance reflects a high degree of component reliability, and as such, no compensatory measures are necessary.
- 7. It is requested that enforcement discretion for non-compliance with TS Action 3.6.1.3.A be in effect for 45 days to allow time for processing of an exigent TS Amendment request. Past testing and inspection demonstrates the functional condition of the valve, and provides reasonable assurance of performance.
- 8. The requested enforcement discretion has been approved by the Plant Operations Committee.
~j
, ~
~ t REQUEST FOR ENFORCEMENT DISCRETION FROM REQUIRED ACTIONS OF t
TECHNICALSPECIFICATION 3.6.1.3.A
- 9. This requested enforcement discretion meets criterion 1(a) of section B of Part 9900.
Enforcement discretion is required to avoid the transient associated with a forced plant shutdown which would result from long term isolation of the TIP penetration. The Supply System considers repetitive opening of TIP-V-15 under administrative controls, as permitted by TS 3.6.1.3, to be undesirable.
- 10. An exigent TS Amendment request. will be submitted to the staff within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Attached is marked-up page 5.0-11 showing the proposed change.
- 11. Adoption of "Improved" Technical Specifications at WNP-2 has not eliminated the need for this request for enforcement discretion.
- 12. The Supply System knows of no additional information that willbe needed by the staff.
Should you have any questions or desire additional information regarding this matter, please contact P. J. Inserra at (509) 377-4147.
Respectfully, J.V. Parrish
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Chief Executive Officer Mail Drop 1023 Attachment EW Merschoff - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office TG Colburn - NRR NRC Sr. Resident Inspector - 927N DL Williams - BPA/399 PD Robinson - Winston & Strawn