ML17277B401

Application for Amend to License NPF-21,changing Tech Specs to Allow Suspension of Containment Inerting During Power Ascension Test Program Until Rated Thermal Power Trip Tests Completed.Fee Encl

ML17277B401
Person / Time
Site:	Columbia
Issue date:	05/11/1984
From:	SORENSEN G C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	SCHWENCER A Office of Nuclear Reactor Regulation
Shared Package
ML17277B402	List: ML17277B401 ML17277B404
References
GO2-84-298, NUDOCS 8405160249
Download: ML17277B401 (7)

Text

REGULATORY lelORMATION DISTRIBUTION SYSt (RIBS)ACCESSION NBR;8405160249 DOC;DATE: 84/05/11 NOTARIZED:

YES DOCKET FACIL:50 397 IIPPSS Nuc.lear Projects Unit 2g Washington Public Ppwe 05000397 AUTH INANE AUTHOR AFFILIATION SORENSEN<G.C, Hashinaton Public Power Supply System RECIP~NAME REC'LPIEN'f AFF.IlIATION SCHIPENCKRgA

~L'icensing Branch 2 SUBJECTS Application for amend to L'icynse NPF-21ichanging Tech Specs to.allow suspension of containment>>

inerting during power ascension test orooram until rated thermal mower: trio tests completed.Fee encl.DISTRIBUTION CODK: A001S COPIES RECEIVED:LTR g ENCL g SIZE!-jan@'lTLK!

OR Submittal:

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Nr.A.Schwencer, Chief Licensing Branch No.2 Division of Licensing U.S.Nuclear Regulatory Commission Washington, D.C.20555

References:

1).2}NUCLEAR PLANT NO.2 OPERATING LICENSE NPF-21, RE(VEST FOR AMENDMENT, SPECIAL TEST EXCEPTION 3/4.10.5, OXYGEN CONCENTRATION Letter, G02-83-900, G.C.Sorensen (SS)to A.Schwencer (NRC},"Exemption Request to NUREG-0123, Standard BWR Technical Specifications", dated October 10, 1983 Letter, T.N.Novak (NRC)to G.C.Sorensen (SS),"WPPSS Nuclear Project No.2-Request for Exemption From l0 CFR 50.44 Regarding Containment Inerting", dated, December.15, 1983 Title 10, Code of Federal Regulations, Part 50.44, Standards for Combustible Gas Control System in Light Water Cooled Power Reactors Federal Register (FR), April 6, 1983, pages 14864-14880, Standards for Determining Whether License Amendments Involve No Significant Hazards Considerations Reference 1 requested the subject technical specification allow 120 Effective Full Power days prior to requiring containment inerting instead of the pre-sently worded technical specification:

"6 months after initial criticality".

Reference 2 denied that.request but did commit to consider a new request if two-to-three months after initial criticality it was determined that the power ascension test program (PATP)could not be completed within six months.S~OSSaOa49 S40Siz PDR*DQCK 0500039T P PDR L

A.Schwencer Page Two With WNP-2 achieving initial criticality January 19, 1984, the present tech-nical specification would require inerting by July 19, 1984.Continuation of the PATP beyond this date with an inerted containment and the high frequency of containment entries requiring deinerting would severely impact the present schedule and significantly delay commercial operations.

Information provided by reference 1 indicated that the average PATP period for the last nine (9)domestic BWR startups, excluding LaSalle 1, was 330 days.The program for Susquehanna 1 took 254 days and LaSalle 1, 568.Due to the reasons identified below, the present projected completion for WNP-2 is September 6, 1984.This date has no contingency"cushion" and contains no allowances for unscheduled equipment repairs or required retesting.

Accordingly, the Supply System hereby requests the subject technical speci-fication be changed (as attached)to allow suspension of containment inerting during the power ascension test program until either the required 1001 of Rated Thermal Power Trip Tests have been completed or the reactor has operated-for 120 Effective Full Power Days.It should be noted that this technical specification change request also represents a request for exemption from reference 4, paragraph (c)(3)(i)which states: "Effective Hay 4, 1982 or 6 months after initial criticality, whichever is later, an inerted atmosphere shall be provided for each boiling water nuclear power reactor with a Hark I or Hark II type containment...".

The reason the WNP-2 PATP is being extended beyond six (6)months is the amount of plant testing'ccomplished between fuel load and five percent (5Ã)power.In order to expedite moving from a construction phase to the power ascension program, the Supply System chose to defer a significant amount of system testing normally done prior to fuel load.This is reflected in the list of preoperational and acceptance tests in attachment 1 to the WNP-2 operating license.The overall affect of deferral on scheduling was beneficial; however, it did move more work and plant evolutions into the six (6}month period thereby extending that interval.The Supply System has reviewed the technical specification change per 10 CFR 50.59 and 50.92 and considers that no significant hazards or unreviewed safety questions will result from the change.The proposed change will not: 1}involve a significant increase in the probability or consequences of an accident previously evaluated; or 2}create the possibility of a new or different kind of'accident from any accident previously evaluated; or.3}involve a significant reduction in a margin of safety.

c A.Schwencer Page Three With regard to 10 CFR 50.92, the Supply System has determined that this change does not involve a significant hazards consideration.

It has been a long established NRC staff policy to permit the operation of boiling water plants during start-up testing with non-inerted containments.

The high frequency of containment entries during this period of plant operations make it impractical to operate with an inerted containment.

This matter has been reviewed and found.acceptable by the staff in a number of prior cases.The staff has found that exemption from 10 CFR 50.44 can be granted and does not endanger life or property or the common defense and security and is otherwise in the public interest.(See LaSalle Unit 1 Operating License NPF-11, Amendment No.12,and'supporting SER, dated December 20, 1982).Additionally, the staff has previously determined that similar technical specification amendments and exemptions to 10 CFR 50.44 do not authorize a change in effluent types of total amount nor an increase in power level and would not result in any significant environmental impact.Further, the staff has concluded that similar amendments and exemptions involve actions which are insignificant from the standpoint of environmental impact.Hence, the Supply System concludes that this change does not involve a significant hazards consideration and cites example (vi)of reference 4 in justification.

The Supply System has evaluated this request in accordance with the criteria in 10 CFR 170.22 and has determined this request to be a Class III request, having acceptability--clearly.

identified by an NRC position and deemed not to involve a significant hazards consideration.

Accordingly, a check for Four thousand dollars ($4,000)is enclosed in payment for this license amendment.

In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.Should you have any questions, please contact Nr.P.L.Powell, Manager, WNP-2 Licensing.

Yery truly yours, G.C.Sorensen, Hanager Regulatory Programs PLP/tmh Attachment cc: R Auluck WS Chin ND Lewis D Hoffman AD Toth-NRC-BPA-EFSEC-NRC'NRC Site