ML17277B601

Application for Amend to License NPF-21,changing Condition 28 Deadline for Environ Qualification of Electrical Equipment Per 10CFR50.49 from 850331 to 1130. Equipment Justification Encl

ML17277B601
Person / Time
Site:	Columbia
Issue date:	01/30/1985
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Schwencer A Office of Nuclear Reactor Regulation
References
GO2-85-048, GO2-85-48, TAC-57169, TAC-59516, NUDOCS 8502050078
Download: ML17277B601 (13)

Text

5'-/i'.r u'4 REGULATOR1 INFORMATION DISTRIBUTION b STEM (RIDS)

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NBR:8502050078 DOC ~ DATE: 85/01/30, NOTARIZED: NO DOCKET Nuclear Pro.lect'nit 2i Washington Public

'CCESSION FACIL:50-397 NPPSS Powe 05000397 AUTH INANE A/THOR AFFILIATION SORENSENiG.C. Washington Public Power Supply System RECIP ~ NAME RECIPIENT AFFILIATION SCH'AENCERgA ~ Licensing Branch 2

SUBJECT:

Application for; amend to License NPF,2iichanging, Condition 28 deadline for envirop qual,ification of electrical equipment per 10CpR50.49 from 850331 to 1130 ~

Equipment .Justification CODE: A048D, COPIES RECEIVED:LTR encl'ISTRIBUTION

'NCL SI E'o TITLE: OR/Licensing Submittal: Equipment Qual ification NOTES: 05000397 OL: 12/20/83 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME NRR LB2 BC LTTR ENCL 1 0 ID CODE/NAtdE AULUCKiR 01 1,1 LTTR ENCL ADM/LFMB 12'NTERNAL:

ACRS 15 8 8 1= 0 ELD/HDS2 12 1 1 GC ,

13 NRR KARSCHiR 1 1 ,NRR/DE/EQB 07 2 2 NRR/DL DIR 14 1 1 NRR/DL/ORAB 06 1 1 NRR/DS I /AEB 1 1 04 1 1 RGN5 1 1 EXTERNAL: LPDR 03 1 1 NRC PDR NSIC 05- 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL, 22

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Washington Public Power Supply System P.O. Box 968 3000 George Washington Way Richland, Washington 99352 (509) 372-5000 January 30, 1985 G02-85-048 Docket No. 50-397 Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, 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 AMENDMENT TO LICENSE CONDITION (28)

Reference:

1) Letter, UL NRC-1006, D. F. Schnell (Union Electric Company} to H. R. Denton (NRC), "Callaway Plant Unit 1, Revision to License Condition 2.C.(3)(a)",

dated December. 28, 1984.

=2} Letter, G02-85-021, G. C. Sorensen (SS) to A.

Schwencer (NRC), "Operating License NPF-21, Request for Amendment to License Condition (28) and Environ-mental gualification '10 CFR 50.49(h) Notification",

dated January 17, 1985 This amendment application requests that the March 31, 1985 deadline stated in the subject license condition be changed to November 30, 1985. At present, License Condition .(28} requires that "prior to March 31, 1985, the licensee shall environmentally qualify all electrical equipment according to the provisions of 10 CFR 50.49". Recent discussions with the Staff indicate that the appropriate section of'he rule applicable to WNP-2 is 10 CFR 50.49(i) which does not stipulate a qualification deadline for applicants granted licenses on or after February 22, 1983. (The WNP-2 license was issued

,December. 20, 1983.}

The March,31, 1985 date is mentioned in 10 CFR 50.49(g) which is applicable to "each holder'f an operating license issued prior to February 22, 1983".

Since the rule, does not appear to impose the March 31, 1985 deadline on the WNP-2 license, the requested amendment does not involve an exemption to 10 CFR 50.49. In fact, consistent with the request, 10 CFR 50.49(g) permits the Staff to extend the compliance deadline to November 30, 1985, for those operating licenses issued prior to February 22, 1983, where appropriate JIO's are provided.

8502050078 850i30 PDR ADOCK 05000397 p PDR

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A. Schwencer Page Two January 30, 1985 REQUEST FOR AMENDMENT TO LICENSE CONDITION (28)

Although the deadlines given in 10 CFR 50.49(g) are not expressly applicable to WNP-2, it is understood that:

a) explicit Commission approval is required for extensions past November 30, 1985; and, b) precedents have been established in recently issued operating licenses that included the November 30, 1985 qualification deadline.

Specifically, NPF-23 issued to Byron Station Unit 1 has November 30, 1985 as the environmental qualification deadline. Additionally, Callaway Plant Unit 1, NPF-30, has recently requested the same change to the license condition addressing environmental qualification in the Callaway license (Reference 1).

In support of this amendment request, the Supply System has reviewed all the JIO's applicable to WNP-2 and concluded that they will remain valid and effective through November, 30, 1985. The Supply System review of the Justifi-cation for Interim Operation reveals that Table A, Page 3 should include CIA-V-39A. Equipment Justification,82 discusses and includes justification for this valve. Further justification is not necessary. Additionally, Page A-27 should include REA-E/P-1A.- A 'Justification for Interim Operation is attached for this device. The discussions provided by these JIO's ensure that the plant can be safely operated, pending completion of equipment qualification.

The issue at question ls.not one, of compliance with the regulation, rather it is the date by which the compliance is achieved. It is noted that the Staff has concluded that the Supply System has demonstrated conformance with the qualification requirements of 10 CFR 50.49 (Supplement 4 to WPPSS Nuclear Project No. 2 Safety Evaluation, Report, NUREG-0892, Section 3.11.5).

Pursuant to the above information, this amendment request does not adversely affect or endanger the health of the general public and does not involve an unreviewed safety .question.

The Supply System has reviewed this change per 10 CFR 50.92 and the guidance provided by the Staff in applying the standards of 10 CFR 50.92 (48 FR 14870) and determined that this change does not involve a significant hazard. This change is similar to the example of an action involving no significant hazards consideration which relates to a change to make the license conform to regula-tions, where the license amendment, results in very minor changes to facility operations clearly in. keeping with the regulations.

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A. Schwencer Page Three January 30, 1985 RE(VEST FOR AMENDMENT TO LICENSE CONDITION (28)

This amendment request does not involve a significant increase in the prob-ability or consequences of an accident or other adverse condition over previous evaluations (the requested amendment does not constitute a significant change to the licensing basis of the plant); nor create the possibility of a new or different kind of accident or condition over previous evaluations (no changes are being made to any equipment and/or systems, and therefore no new or different kinds of accidents would be made possible); nor involve a signifi-cant reduction in a margin of safety (no original design parameters are being reduced). Based on the foregoing, the requested amendment does not present a significant hazard.

It should be noted that this request supercedes that requested in Reference 2 and the warrant provided with Reference 2 should be applied as initial payment for this amendment request per 10 CFR 170.21 Category A (Power Reactors).

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 Hr. P. L. Powell, Manager, WNP-2 Licensing. As you are aware, prompt attention to this amendment is necessary; continued operation of WNP-2.requires approval of this amendment no later than Harch 31, 1985.

Yery truly yours,

~.Regulatory C. Sorensen, Manager Programs PLP/tmh cc: R Auluck - NRC WS Chin - BPA N Lewis - EFSEC JB Hartin NRC RV A Masciantonio - NRC AD Toth - NRC Site

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~ Q E UIPMENT JUSTIFICATION

1. 0 COMPONENT IDENTIFICATION EPN: REA- E/P-1A

Description:

Fan Damper Electro-Pneumatic Converter Manufacturer/Model: Moore Industries/77-16 2.0 ACCIDENT CONDITIONS Tem erature Relative Humidit Accident Profile: 1/4, 21X Use Code: 2Gl Operability Time: 4320 Hours Radiation Zone: 572C Zone Dose: 3.0 x 104 3.0 COMPONENT SAFETY FUNCTION This passive device must maintain electrical integrity during a high humidity condition resulting from a high energy line break for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4. 0 UALI F I CATI ON STATUS 4.1 Summar of uglification Status REA-E/P-1A is located in a relatively mild environment for temperature and pressure. It is exposed to 1005 relative humidity due to High Energy Line Break. The equipment has not been tested for 100'A relative humidity.

The equipment is to be replaced with equipment with available qualification documentation.

4. 2 Parameters Re uirin Jus ti fi cati on Humi di ty.

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5.0 JUSTIFICATION FOR INTERIM OPERATION',

The component is rated as NEMA 3R, which means it can be applied in outdoor use and has passed rain tests. Additionally, the transducer's exhaust provides an air purge of the terminal enclosure. The duration of the accident during which it would experience high relative humidity is short (i.e., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). The equipment is required only to maintain electrical integrity for this period. No significant degradation is likely to occur which would compromise this minimal function during this period.

6.0 CONCLUSION

Interim operation is justified on the following basis:

The device housing is resistant to ivater, the duration of the high humidity condition is short, and the required function is likely to be protected.

WNP-2 OL NPF-21 RE(}UEST FOR LICENSE AMENDMENT TO LICENSE STATE OF WASHINGTON )

Subject:

CONDITION (28)

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County of Benton )

I, R. B. GLASSCOCK, 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 , 1985 asscoc , iree or Licensing and Assurance On this day personally appeared before me R. B. GLASSCOCK 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 3 / day of , 1985.

otary Public in and for the State of Washington Residing at

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