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| | issue date = 09/02/1992 | | | issue date = 09/02/1992 |
| | title = Application for Amend to License NPF-21,changing TS 3/4.3.7.6 Re Source Range Monitor Surveillance Criteria Specified in LCO to Incorporate Guidance in Rev 1 of GE Svc Info Ltr Covering Channel Rate Count | | | title = Application for Amend to License NPF-21,changing TS 3/4.3.7.6 Re Source Range Monitor Surveillance Criteria Specified in LCO to Incorporate Guidance in Rev 1 of GE Svc Info Ltr Covering Channel Rate Count |
| | author name = SORENSEN G C | | | author name = Sorensen G |
| | author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM | | | author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| | addressee name = | | | addressee name = |
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| | document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS | | | document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS |
| | page count = 9 | | | page count = 9 |
| | | project = |
| | | stage = Request |
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| {{#Wiki_filter:ACCELERATED D" RIBUTION DEMON<RATION SYSTEM REGULATQ INFORMATION DISTRIBUTION STEM (RIDS)(~ACCESSION NBR:920'P140105 DOC.DATE: 92/09/02 NOTARXZED: | | {{#Wiki_filter:ACCELERATED D " RIBUTION DEMON< RATION SYSTEM REGULATQ INFORMATION DISTRIBUTION STEM (RIDS) |
| YES FACXL: 50-397 MPPSS Nuclear Pro Jecti Unit 2i Mashington Public Poee AUTH.NANE AUTHOR AFFILIATION SORENSENi G.C.4lashing ton Public Power Supply System REC I P.NANE RECXP XENT AFFILXATXON Document Control Branch (Document Control Desk)DOCKET 0 05000397 | | (~ |
| | ACCESSION NBR:920'P140105 DOC. DATE: 92/09/02 NOTARXZED: YES DOCKET 0 FACXL: 50-397 MPPSS Nuclear Pro Jecti Unit 2i Mashington Public Poee 05000397 AUTH. NANE AUTHOR AFFILIATION SORENSENi G. C. 4lashing ton Public Power Supply System REC I P. NANE RECXP XENT AFFILXATXON Document Control Branch (Document Control Desk) |
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| ==SUBJECT:== | | ==SUBJECT:== |
| Application For amend to License NPF-21>changing TS 3/4.3.7.6 re source range monitor surveillance criteria specified in LCO to incorporate guidance in Rev 1 of GE svc info ltr covering channel rate count.DISTRIBUTION CODE: AOOID COPIES'ECEIVED! | | Application For amend to License NPF-21> changing TS 3/4. 3. 7. 6 re source range monitor surveillance criteria specified in LCO to incorporate guidance in Rev 1 of GE svc info ltr covering channel rate count. |
| LTR'i ENCL/SIZE: TITLE: OR Submittal:
| | DISTRIBUTION CODE: AOOID TITLE: OR COPIES'ECEIVED! LTR Submittal: General Distribution |
| General Distribution D NOTES: RECIPIENT'ID CODE/NANE PD5 LA DEAN>M.COPIES LTTR ENCL 1 1 2 2 RECZPZENT ID CODE/NANE PD5 PD COPIES LTTR ENCL 1 1 INTERNAL: ACRS NRR/DOEA/OTSB11.
| | 'i ENCL / SIZE: |
| NRR/DST/SICBSH7 NUDOCS-ABSTRACT OGC/HDS1 RES/DS IR/EI 8 6 6 1 1 1 1 1 1 1 0 1 1 NRR/DET'/ESGB NRR/DST/SELB,7E'RR/DST/SRXB 8E'C/LF 01 1 1 1 1 1 1 0 1 1 EXTERNAL:.
| | D NOTES: |
| NRC PDR NSIC S NOTE TO ALL"RIDS" RECIPIENTS: | | RECIPIENT COPIES RECZPZENT COPIES |
| PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK.ROOM Pl-37 (EXT.504-2065)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 20 | | 'ID CODE/NANE LTTR ENCL ID CODE/NANE LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 DEAN> M. 2 2 INTERNAL: ACRS 6 6 NRR/DET'/ESGB 1 NRR/DOEA/OTSB11. 1 1 NRR/DST/SELB,7E'RR/DST/SRXB 1 1 NRR/DST/SICBSH7 1 1 1 1 NUDOCS-ABSTRACT 1 1 8E'C/LF 1 0 OGC/HDS1 1 0 01 1 1 RES/DS IR/EI8 1 1 EXTERNAL:. NRC PDR NSIC S |
| ~,~0 4 WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Bm968~3000George Wasbtngton Way~Rtcbland, Wasbtngton 99352C968~(509)372-5000 September 2, 1992 G02-92-208 Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen: | | NOTE TO ALL "RIDS" RECIPIENTS: |
| | PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK. |
| | ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED! |
| | TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 20 |
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| | WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Bm968 ~ 3000George Wasbtngton Way ~ Rtcbland, Wasbtngton 99352C968 ~ (509)372-5000 September 2, 1992 G02-92-208 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen: |
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| ==Subject:== | | ==Subject:== |
| WNP-2, OPERATING LICENSE NPF-21 RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.3.7.6 SOURCE RANGE MONITORS | | WNP-2, OPERATING LICENSE NPF-21 RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.3.7.6 SOURCE RANGE MONITORS |
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| ==Reference:== | | ==Reference:== |
| | : 1) General Electric Service Information Letter No. 478, "SRH Minimum Count Rate," dated December 16, 1988 |
| | : 2) Letter G02-92-016, dated January 21, 1992, GC Sorensen (SS) to NRC, "Request for Amendment to TS Limiting Condition for Operability 3/4.9.2 Source Range Monitor Operability, Re-fueling Operations" |
| | : 3) Letter, dated April 10, 1992, WH Dean (NRC) to GC Sorensen (SS), "Issuance of Amendment for the Washington Public Power Supply System Nuclear Project No. 2 (TAC No. H82662)" |
| | In accordance with the Code of Federal Regulations, Title 10 Parts 50.90 and |
| | : 2. 101, the Supply System hereby submits a request for amendment to the WNP-2 Technical Specifications. This proposal requests that source range monitor (SRM) surveillance criteria specified in the subject Limiting Condition for Operation be changed (as attached) to incorporate the Reference 1 Service Information Letter (SIL) guidance. The SIL guidance modifies the acceptable SRH channel count rate and signal-to-noise ratio values to maintain the General Electric design confidence level. |
| | This same change was requested in Reference 2. However because the primary purpose of Reference 2 was to request changes in the Refueling Instrumentation Technical Specification SRM requirements to allow a complete core offload the applicability of the SIL guidance to Specification 3/4.3.7.6 was not recognized. |
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| 1)General Electric Service Information Letter No.478,"SRH Minimum Count Rate," dated December 16, 1988 2)3)Letter G02-92-016, dated January 21, 1992, GC Sorensen (SS)to NRC,"Request for Amendment to TS Limiting Condition for Operability 3/4.9.2 Source Range Monitor Operability, Re-fueling Operations" Letter, dated April 10, 1992, WH Dean (NRC)to GC Sorensen (SS),"Issuance of Amendment for the Washington Public Power Supply System Nuclear Project No.2 (TAC No.H82662)" In accordance with the Code of Federal Regulations, Title 10 Parts 50.90 and 2.101, the Supply System hereby submits a request for amendment to the WNP-2 Technical Specifications.
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| This proposal requests that source range monitor (SRM)surveillance criteria specified in the subject Limiting Condition for Operation be changed (as attached)to incorporate the Reference 1 Service Information Letter (SIL)guidance.The SIL guidance modifies the acceptable SRH channel count rate and signal-to-noise ratio values to maintain the General Electric design confidence level.This same change was requested in Reference 2.However because the primary purpose of Reference 2 was to request changes in the Refueling Instrumentation Technical Specification SRM requirements to allow a complete core offload the applicability of the SIL guidance to Specification 3/4.3.7.6 was not recognized.
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| I Page 2 RE(UEST FOR AMEND.TO TS LCO 3/4.3.7.6 SOURCE RANGE MONITORS The SRHs provide the operator with information relative to the neutron level at very low flux levels.As such, the SRH indication is used to determine the approach to criticality and when criticality is achieved.The SRHs provide monitoring of reactivity changes during fuel or control rod movement and give the control room operator early indication of unexpected subcritical multiplication that could be indicative of an approach to criticality.
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| Although no credit is taken for SRM function in any WNP-2 design basis accident or transient analysis they do provide indication to the operator that aids in reactor control.The Reference I SIL provides guidan'ce to modify the SRH count rate to ensure that the design 95%confidence level is maintained in verifying SRH operability.
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| As stated in the SIL, the acceptable SRH count rate value based on signal-to-noise (S/N)ratio has not been consistent within the BWR community.
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| As a result of inquiries from some BWRs, General Electric conducted studies showing that a 95%confidence level can be preserved by specifying either 0.7 counts per second (cps)with a-S/N>20 or 3 cps with a S/N>2.As stated above, Reference 2 requested this change for Technical Specification 3/4.9.2 (Refueling Operations).
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| Reference 3 issued the change for implementation at WNP-2.The change is also appropriate for Specification 3/4.3.7.6.
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| The Supply System has evaluated this change request per 10 CFR 50.92 and determined that it does not represent a significant hazards consideration because it does not: I)Involve a significant increase in the probability or consequences of an accident previously evaluated.
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| The SRH instrumentation is not assumed to be an initiator of any analyzed event.The SRH instrumentation provides monitoring of neutron flux levels to give the control room operator early indication of unexpected subcritical multiplication that could be indicative of an approach to criticality.
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| As such, action could be taken on the indication to avert or minimize the consequences of the event.However, the SRH function is not relied upon in any design bases or transient analysis.Rod motion interlocks and other instrumentation are relied on in the accident analysis to avert an accident.The change in acceptable count rate and signal-to-noise ratio preserves the confidence level of the General Electric design.As a result, the consequences of any analyzed events are unaffected because the change does not alter any system or component design assumptions or operation.
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| Therefore, no significant increase in the probability or consequences of an accident previously evaluated will be involved.2)Create the possibility of a new or different kind of accident from any accident previously evaluated.
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| The proposed change in SRH count rate and S/N ratio values does not create the possibility of a new or different kind of accident from any previously evaluated because it does not change modes of plant operation or require physical modifications.
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| The change preserves the original General Electric design confidence level.No new or different kind of accident is therefore credible.
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| I I J Page 3 RE(VEST FOR AHEND.TO TS LCO 3/4.3.7.6 SOURCE RANGE HONITORS 3)Involve a significant reduction in a margin of safety.The change in SRH count rate and S/N ratio values does not affect a margin of safety because the values preserve the original General Electric design confidence level.Therefore, no margin of safety is impacted by this change.As discussed above, the Supply System concludes that this change does not involve a significant hazards consideration, nor is there a potential for significant change in the types or significant increase in the amount of any effluents that may be released offsite, nor does the change involve a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(C)(9) and therefore, per 10 CFR 51.22(b), an environmental assessment of these changes is not required.This Technical Specification change request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board.In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.Very truly yours,-Q/G.C.So ensen, Hanager Regulatory Programs (Hail Drop 280)PLP/bk Attachments cc: RG Waldo-EFSEC JB Hartin-NRC RV NS Reynolds-Winston S.Strawn RR Assa-NRC DL Williams-BPA/399 NRC Site Inspector-901A
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| STATE OF WASHINGTON)
| | I Page 2 RE(UEST FOR AMEND. TO TS LCO 3/4.3.7.6 SOURCE RANGE MONITORS The SRHs provide the operator with information relative to the neutron level at very low flux levels. As such, the SRH indication is used to determine the approach to criticality and when criticality is achieved. The SRHs provide monitoring of reactivity changes during fuel or control rod movement and give the control room operator early indication of unexpected subcritical multiplication that could be indicative of an approach to criticality. Although no credit is taken for SRM function in any WNP-2 design basis accident or transient analysis they do provide indication to the operator that aids in reactor control. |
| )COUNTY OF BENTON) | | The Reference I SIL provides guidan'ce to modify the SRH count rate to ensure that the design 95% confidence level is maintained in verifying SRH operability. As stated in the SIL, the acceptable SRH count rate value based on signal-to-noise (S/N) ratio has not been consistent within the BWR community. As a result of inquiries from some BWRs, General Electric conducted studies showing that a 95% |
| | confidence level can be preserved by specifying either 0.7 counts per second (cps) with a- S/N > 20 or 3 cps with a S/N > 2. As stated above, Reference 2 requested this change for Technical Specification 3/4.9.2 (Refueling Operations). |
| | Reference 3 issued the change for implementation at WNP-2. The change is also appropriate for Specification 3/4.3.7.6. |
| | The Supply System has evaluated this change request per 10 CFR 50.92 and determined that it does not represent a significant hazards consideration because it does not: |
| | I) Involve a significant increase in the probability or consequences of an accident previously evaluated. The SRH instrumentation is not assumed to be an initiator of any analyzed event. The SRH instrumentation provides monitoring of neutron flux levels to give the control room operator early indication of unexpected subcritical multiplication that could be indicative of an approach to criticality. As such, action could be taken on the indication to avert or minimize the consequences of the event. |
| | However, the SRH function is not relied upon in any design bases or transient analysis. Rod motion interlocks and other instrumentation are relied on in the accident analysis to avert an accident. The change in acceptable count rate and signal-to-noise ratio preserves the confidence level of the General Electric design. As a result, the consequences of any analyzed events are unaffected because the change does not alter any system or component design assumptions or operation. Therefore, no significant increase in the probability or consequences of an accident previously evaluated will be involved. |
| | : 2) Create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed change in SRH count rate and S/N ratio values does not create the possibility of a new or different kind of accident from any previously evaluated because it does not change modes of plant operation or require physical modifications. The change preserves the original General Electric design confidence level. No new or different kind of accident is therefore credible. |
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| | Page 3 RE(VEST FOR AHEND. TO TS LCO 3/4.3.7.6 SOURCE RANGE HONITORS |
| | : 3) Involve a significant reduction in a margin of safety. The change in SRH count rate and S/N ratio values does not affect a margin of safety because the values preserve the original General Electric design confidence level. |
| | Therefore, no margin of safety is impacted by this change. |
| | As discussed above, the Supply System concludes that this change does not involve a significant hazards consideration, nor is there a potential for significant change in the types or significant increase in the amount of any effluents that may be released offsite, nor does the change involve a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(C)(9) and therefore, per 10 CFR 51.22(b), an environmental assessment of these changes is not required. |
| | This Technical Specification change request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board. In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter. |
| | Very truly yours, |
| | -Q/ |
| | G. C. So ensen, Hanager Regulatory Programs (Hail Drop 280) |
| | PLP/bk Attachments cc: RG Waldo - EFSEC JB Hartin - NRC RV NS Reynolds - Winston S. Strawn RR Assa - NRC DL Williams - BPA/399 NRC Site Inspector - 901A |
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| | STATE OF WASHINGTON) |
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| ==Subject:== | | ==Subject:== |
| Request for Amend to TS Source Ran e Monitors 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 the 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 1992 G.C.Sodensen, Manager Regulatory Programs On this date personally appeared before me G.C.SORENSEN, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned. | | Request for Amend to TS |
| GIVEN under my hand and seal this~day of 1992.No u ic in and for the STATE OF WASHINGTON Residing at Kennewick Washin ton My Commission Expires A ril 28 1994 l S l/~C p'v..Ill,llll4"'}} | | ) Source Ran e Monitors 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 the 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 1992 G. C. Sodensen, Manager Regulatory Programs On this date personally appeared before me G. C. SORENSEN, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned. |
| | GIVEN under my hand and seal this ~day of 1992. |
| | No u ic in and for the STATE OF WASHINGTON Residing at Kennewick Washin ton My Commission Expires A ril 28 1994 |
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Category:OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING
MONTHYEARML17284A9101999-10-13013 October 1999 Application for Amend to License NPF-21,revising TS 3.3.6.1, Table 3.3.6.1-1, Primary Containment Isolation Instrumentation. Footnote (D) Is Removed Since Both Inboard & Outboard Trip Sys Are Now Functional in All Modes ML17284A8501999-07-29029 July 1999 Application for Amend to License NPF-21,revising TS 3.4.9, RHR Shutdown Cooling Sys - Hot Shutdown. ML17284A8471999-07-29029 July 1999 Application for Amend to License NPF-21,revising Tech Specs SR 3.5.2.2, Condensate Storage Tank Water Level. ML17284A8441999-07-29029 July 1999 Application for Amend to License NPF-21,revising TS Table 3.3.5.1-1, ECCS Instrumentation Items 1.a,2.a,4.a & 5.a. ML17284A8431999-07-29029 July 1999 Application for Amend to License NPF-21,removing License Condition 2.C.(16),Attachment 2,Item 3(b) Re post-accident Neutron Flux Monitoring ML17284A8401999-07-29029 July 1999 Application for Amend to License NPF-21,amending Tech Specs SR 3.8.4.6 of TS 3.8.5, DC Sources - Operating & SR 3.8.5.1 of TS 3.8.5, DC Sources - Shutdown. ML17292B6891999-06-0303 June 1999 Application for Amend to License NPF-21,reflecting Change in Name of Washington Public Power Supply Sys to Energy Northwest.Marked-up Copy of Affected Pages of OL for Plant, Encl ML17292B6441999-04-20020 April 1999 Application for Amend to License NPF-21,revising TS 3.4.11 to Replace Existing Reactor Pressure Temp Limit Curves by 000630 ML17292B6321999-04-0707 April 1999 Application for Amend to License NPF-21,requesting Mod to MCPR Safety Limits by 990930 to Allow Continued Power Operation at Plant Following Restart from R-14 RFO ML17292B4861998-12-17017 December 1998 Application for Amend to License NPF-21,revising TS SR 3.8.1.8 to Allow for Capability to Manually Transfer Between Preferred & Alternate Offsite Power Sources During Modes 1 & 2 by 990125 ML17284A8071998-11-0909 November 1998 Supplemental Application for Amend to License NPF-21, Requesting Minor Wording Changes to Clarify Intent of Proposed New License Section 2.B.(6).Addl Info That Describes Physical Storage of Matls,Encl ML17284A7161998-08-0505 August 1998 Application for Amend to License NPF-21,modifying TS SR 3.8.4.7 to Allow Performance Discharge Test to Be Performed in Lieu of Battery Svc Test for Div 1 & 3,125 Vdc Batteries E-B1-1 & HPCS-B1-DG3 & Div 1,250 Vdc Battery E-B2-1 ML17284A7051998-07-17017 July 1998 Application for Exigent Amend to License NPF-21,modifying TS SR 3.8.4.7 to Allow Performance Discharge Test to Be Performed in Lieu of Battery Svc Test for Div 2,125 Vdc, Battery E-B1-2 ML17292B3401998-04-16016 April 1998 Application for Amend to License NPF-21,modifying Requirement That cold-worked Austenitic Stainless Steel Used in Newly Designed ECCS Pump Suction Strainers Must Have Yield Strength Not Greater than 90,000 Psi ML17292B1301997-12-0404 December 1997 Application for Amend to License NPF-21,modifying Min Critical Power Ratio Safety Limits by 980515 to Allow Continued Power Operation at WNP-2 Following Restart from R-13 Refueling Outage ML17292B0261997-08-14014 August 1997 Application for Amend to License NPF-21,modifying Inservice Testing Requirements Specified in TS 5.5.6 for Inboard Primary Containment Isolation Valve on Transvering in-core Probe (TIP) Sys Nitrogen Purge Line ML17292A9401997-07-16016 July 1997 Application for Amend to License NPF-21,adding New Min Reactor Vessel Pressure Versus Reactor Vessel Metal Temp (P/T) Curves,Applicable Up to 12 Efpys.Changes Support Vessel Leak Testing ML17292A8631997-05-20020 May 1997 Application for Amend to License NPF-21,requesting Mod of Minimum Critical Power Ratio Safety Limits by 970615 ML17292A7561997-03-22022 March 1997 Application for Amend to License NPF-21,modifying Response Time Testing Surveillance Requirements for RPS Instrumentation,Primary Containment Isolation Actuation Instrumentation & ECCS Actuation Instrumentation ML17292A5491996-10-15015 October 1996 Application for Amend to License NPF-21 to Modify TS for Secondary Containment & Standby Gas Treatment Sys to Reflect Revised Secondary Containment Drawdown & post-accident Analyses Results.Affidavit,Encl ML17292A5381996-10-10010 October 1996 Application for Amend to License NPF-21,requesting Addition of Section 2B(6) Re Allowance of Storage of Byproduct, Source & Special Nuclear Materials ML17292A4081996-08-0909 August 1996 Requests Amend to License NPF-21,revising TS Section 6.3 Re Unit Staff Qualifications,By Changing Operations Manager Qualification Requirements Associated W/Operations Knowledge from Meeting Ansi/Ans N18.1-1971 GO2-96-089, Application for Amend to License NPF-21,modifying TS to Support Cycle 12,scheduled to Begin Subsequent to Spring 1996 Outage1996-04-24024 April 1996 Application for Amend to License NPF-21,modifying TS to Support Cycle 12,scheduled to Begin Subsequent to Spring 1996 Outage ML17291B2781996-03-19019 March 1996 Application for Amend to License NPF-21,revising Containment Leakage Testing ML17291B2071996-01-19019 January 1996 Application for Amend to License NPF-21 Re Primary Containment Leakage Testing GO2-95-265, Application for Amend to License NPF-21,revising TS to Be Consistent w/NUREG-1434, STS GE Plants,Bwr 6, Including Improved TS Submittal,Consisting of Application of Selection Criteria,Ts,Comparison Document & NSHC1995-12-0808 December 1995 Application for Amend to License NPF-21,revising TS to Be Consistent w/NUREG-1434, STS GE Plants,Bwr 6, Including Improved TS Submittal,Consisting of Application of Selection Criteria,Ts,Comparison Document & NSHC ML17291B0921995-10-26026 October 1995 Application for Amend to License NPF-21,revising TS to Reflect Replacement of Existing Reactor Recirculation Flow Control Sys W/Adjustable Speed Drive Sys ML17291A8421995-06-0606 June 1995 Application for Amend to License NPF-21,changing TS 6.0, Administrative Controls by Revising Assistant Managing Director,Operations & Plant Manager Position Titles ML17291A8381995-06-0606 June 1995 Application for Amend to License NPF-21,modifying Index of TS by Deleting Ref to Bases Pages.Future Changes to Bases Info Will Be Evaluated Per 10CFR50.59 ML17291A8321995-06-0606 June 1995 Application for Amend to License NPF-21,modifying TS 6.9.3.2 by Adding Re to Three TRs Describing Analytical Methods That May Be Used in Determining Reactor Core Operating Limits for Reload Licensing Applications,Consistent W/Gl 88-16 ML17291A7551995-04-25025 April 1995 Application for Amend to License NPF-21,adding RWCU Sys High Blowdown Containment Isolation Trip Function & Associated LCO & SRs to Tables 3.3.2-1,3.3.2-2 & 4.3.2.1-1 ML17291A4791994-10-31031 October 1994 Application for Amend to License NPF-21,revising TSs to Relocate Safety/Relief Valve Position Indication Instrumentation Requirements ML17291A4741994-10-31031 October 1994 Application for Amend to License NPF-21,revising TS 3/4.1.3.1, Reactivity Control Sys. ML17291A4201994-09-26026 September 1994 Suppl to 930709 Application for Amend to License NPF-21 Re Increase in Power Operation,Changing Power/Flow Maps in TS 3/4.2.6,3/4.2.7,3/4.2.8 & 3/4.4.1 & Bases to Reflect Use of Siemens Power Corp Staif Code for Stability Analysis ML17291A3941994-09-18018 September 1994 Application for Amend to License NPF-21,changing TS Table 3.6.3-1 Re Primary Containment Isolation Valve Requirements ML17291A3171994-08-0808 August 1994 Application for Amend to License NPF-21,amending TS 4.0.5, Surveillance Requirements for Inservice Insp & Testing Program. ML17291A2151994-07-12012 July 1994 Application for Amend to License NPF-21,requesting Amend to Ts,Relocating TS Table for Instrument Response Time Limits ML17291A2201994-07-0808 July 1994 Application for Amend to License NPF-21,revising TS W/Regard to Control Rod Scram Insertion Testing Under Emergency Circumstances ML17290B1711994-05-0606 May 1994 Application for Amend to License NPF-21,revising TSs 3/4.3.7.5,3/4.4.2 & 3/4.5.1 for Main Steam Relief Valve Position Indication ML17290B1551994-05-0505 May 1994 Application for Amend to License NPF-21,requesting Mod of Three Equipment Piece Numbers Included in Table 3.6.3-1, Primary Containment Isolation Valves. ML17290A9631994-02-17017 February 1994 Application for Amend to License NPF-21,revising TS to Support Hydrostatic Testing ML17290A9601994-02-17017 February 1994 Application for Amend to License NPF-21,revising TS Section 6.0, Administrative Controls, Including Changing Reporting Relationship for QA Functions in Section 6.2.1.e of TS from Managing Director to Assistant Managing Director,Operations ML17290A9551994-02-0808 February 1994 Application for Amend to License NPF-21,consisting of Changes to TS Table 3.6.3-1,for RCIC-V-8,increasing Stroke Time from 13 Seconds to 26 Seconds & Deleting Note (J) Reference from RCIC-V-8 & RCIC-V-63 ML17290A9031994-01-13013 January 1994 Application for Amend to License NPF-21,requesting Continued Plant Operation W/Eccs Functional,But Not in Strict Compliance W/Requirements for Demonstrating That Response Time within Limits of TS 3/4.3.3, ECCS Instrumentation. ML17290A8961994-01-0606 January 1994 Application for Amend to License NPF-21,requesting Changes to TS to Clarify Instrumentation Testing Requirements ML17290A8781994-01-0606 January 1994 Application for Amend to License NPF-21,requesting Rev to TS to Relocate Requirements for Seismic Monitoring Instrumentation to FSAR & Plant Procedures ML17290A8921994-01-0606 January 1994 Suppl to 930709 Application for Amend to License NPF-21, Increasing Licensed Power Level from 3,323 Mwt to 3,486 Mwt W/Extended Load Line Limit & Changing SRV Setpoint Tolerance to Include Changes to TS Paragraph 6.9.3.2 ML17290A8391993-12-20020 December 1993 Application for Amend to License NPF-21,revising TS 3/4.6.1.8, Drywell & Suppression Chamber Purge Sys. ML17290A8181993-12-0606 December 1993 Application for Amend to License NPF-21,requesting TS Surveillance Requirement 4.6.6.1.b.3 Be Revised to Provide Appropriate Acceptance Criteria for Demonstrating Operability of Primary Containment Hydrogen Recombiner Sys ML17290A8221993-12-0606 December 1993 Application for Amend to License NPF-21,adding Footnote to TS Table 4.3.7.5-1, Accident Monitoring Instrumentation Srs, Exempting Channel Calibr of Safety/Relief Valve Position Indicators from Spec 4.0.4 for 24 H 1999-07-29
[Table view] Category:TEXT-LICENSE APPLICATIONS & PERMITS
MONTHYEARML17284A9101999-10-13013 October 1999 Application for Amend to License NPF-21,revising TS 3.3.6.1, Table 3.3.6.1-1, Primary Containment Isolation Instrumentation. Footnote (D) Is Removed Since Both Inboard & Outboard Trip Sys Are Now Functional in All Modes ML17284A8501999-07-29029 July 1999 Application for Amend to License NPF-21,revising TS 3.4.9, RHR Shutdown Cooling Sys - Hot Shutdown. ML17284A8471999-07-29029 July 1999 Application for Amend to License NPF-21,revising Tech Specs SR 3.5.2.2, Condensate Storage Tank Water Level. ML17284A8441999-07-29029 July 1999 Application for Amend to License NPF-21,revising TS Table 3.3.5.1-1, ECCS Instrumentation Items 1.a,2.a,4.a & 5.a. ML17284A8431999-07-29029 July 1999 Application for Amend to License NPF-21,removing License Condition 2.C.(16),Attachment 2,Item 3(b) Re post-accident Neutron Flux Monitoring ML17284A8401999-07-29029 July 1999 Application for Amend to License NPF-21,amending Tech Specs SR 3.8.4.6 of TS 3.8.5, DC Sources - Operating & SR 3.8.5.1 of TS 3.8.5, DC Sources - Shutdown. ML17292B6891999-06-0303 June 1999 Application for Amend to License NPF-21,reflecting Change in Name of Washington Public Power Supply Sys to Energy Northwest.Marked-up Copy of Affected Pages of OL for Plant, Encl ML17292B6441999-04-20020 April 1999 Application for Amend to License NPF-21,revising TS 3.4.11 to Replace Existing Reactor Pressure Temp Limit Curves by 000630 ML17292B6321999-04-0707 April 1999 Application for Amend to License NPF-21,requesting Mod to MCPR Safety Limits by 990930 to Allow Continued Power Operation at Plant Following Restart from R-14 RFO ML17292B4861998-12-17017 December 1998 Application for Amend to License NPF-21,revising TS SR 3.8.1.8 to Allow for Capability to Manually Transfer Between Preferred & Alternate Offsite Power Sources During Modes 1 & 2 by 990125 ML17284A8071998-11-0909 November 1998 Supplemental Application for Amend to License NPF-21, Requesting Minor Wording Changes to Clarify Intent of Proposed New License Section 2.B.(6).Addl Info That Describes Physical Storage of Matls,Encl ML17284A7161998-08-0505 August 1998 Application for Amend to License NPF-21,modifying TS SR 3.8.4.7 to Allow Performance Discharge Test to Be Performed in Lieu of Battery Svc Test for Div 1 & 3,125 Vdc Batteries E-B1-1 & HPCS-B1-DG3 & Div 1,250 Vdc Battery E-B2-1 ML17284A7051998-07-17017 July 1998 Application for Exigent Amend to License NPF-21,modifying TS SR 3.8.4.7 to Allow Performance Discharge Test to Be Performed in Lieu of Battery Svc Test for Div 2,125 Vdc, Battery E-B1-2 ML17292B3401998-04-16016 April 1998 Application for Amend to License NPF-21,modifying Requirement That cold-worked Austenitic Stainless Steel Used in Newly Designed ECCS Pump Suction Strainers Must Have Yield Strength Not Greater than 90,000 Psi ML17292B1301997-12-0404 December 1997 Application for Amend to License NPF-21,modifying Min Critical Power Ratio Safety Limits by 980515 to Allow Continued Power Operation at WNP-2 Following Restart from R-13 Refueling Outage ML17292B0261997-08-14014 August 1997 Application for Amend to License NPF-21,modifying Inservice Testing Requirements Specified in TS 5.5.6 for Inboard Primary Containment Isolation Valve on Transvering in-core Probe (TIP) Sys Nitrogen Purge Line ML17292A9401997-07-16016 July 1997 Application for Amend to License NPF-21,adding New Min Reactor Vessel Pressure Versus Reactor Vessel Metal Temp (P/T) Curves,Applicable Up to 12 Efpys.Changes Support Vessel Leak Testing ML17292A8631997-05-20020 May 1997 Application for Amend to License NPF-21,requesting Mod of Minimum Critical Power Ratio Safety Limits by 970615 ML17292A7561997-03-22022 March 1997 Application for Amend to License NPF-21,modifying Response Time Testing Surveillance Requirements for RPS Instrumentation,Primary Containment Isolation Actuation Instrumentation & ECCS Actuation Instrumentation ML17292A5491996-10-15015 October 1996 Application for Amend to License NPF-21 to Modify TS for Secondary Containment & Standby Gas Treatment Sys to Reflect Revised Secondary Containment Drawdown & post-accident Analyses Results.Affidavit,Encl ML17292A5381996-10-10010 October 1996 Application for Amend to License NPF-21,requesting Addition of Section 2B(6) Re Allowance of Storage of Byproduct, Source & Special Nuclear Materials ML17292A4081996-08-0909 August 1996 Requests Amend to License NPF-21,revising TS Section 6.3 Re Unit Staff Qualifications,By Changing Operations Manager Qualification Requirements Associated W/Operations Knowledge from Meeting Ansi/Ans N18.1-1971 GO2-96-089, Application for Amend to License NPF-21,modifying TS to Support Cycle 12,scheduled to Begin Subsequent to Spring 1996 Outage1996-04-24024 April 1996 Application for Amend to License NPF-21,modifying TS to Support Cycle 12,scheduled to Begin Subsequent to Spring 1996 Outage ML17291B2781996-03-19019 March 1996 Application for Amend to License NPF-21,revising Containment Leakage Testing ML17291B2071996-01-19019 January 1996 Application for Amend to License NPF-21 Re Primary Containment Leakage Testing GO2-95-265, Application for Amend to License NPF-21,revising TS to Be Consistent w/NUREG-1434, STS GE Plants,Bwr 6, Including Improved TS Submittal,Consisting of Application of Selection Criteria,Ts,Comparison Document & NSHC1995-12-0808 December 1995 Application for Amend to License NPF-21,revising TS to Be Consistent w/NUREG-1434, STS GE Plants,Bwr 6, Including Improved TS Submittal,Consisting of Application of Selection Criteria,Ts,Comparison Document & NSHC ML17291B0921995-10-26026 October 1995 Application for Amend to License NPF-21,revising TS to Reflect Replacement of Existing Reactor Recirculation Flow Control Sys W/Adjustable Speed Drive Sys ML17291A8421995-06-0606 June 1995 Application for Amend to License NPF-21,changing TS 6.0, Administrative Controls by Revising Assistant Managing Director,Operations & Plant Manager Position Titles ML17291A8381995-06-0606 June 1995 Application for Amend to License NPF-21,modifying Index of TS by Deleting Ref to Bases Pages.Future Changes to Bases Info Will Be Evaluated Per 10CFR50.59 ML17291A8321995-06-0606 June 1995 Application for Amend to License NPF-21,modifying TS 6.9.3.2 by Adding Re to Three TRs Describing Analytical Methods That May Be Used in Determining Reactor Core Operating Limits for Reload Licensing Applications,Consistent W/Gl 88-16 ML17291A7551995-04-25025 April 1995 Application for Amend to License NPF-21,adding RWCU Sys High Blowdown Containment Isolation Trip Function & Associated LCO & SRs to Tables 3.3.2-1,3.3.2-2 & 4.3.2.1-1 ML17291A4791994-10-31031 October 1994 Application for Amend to License NPF-21,revising TSs to Relocate Safety/Relief Valve Position Indication Instrumentation Requirements ML17291A4741994-10-31031 October 1994 Application for Amend to License NPF-21,revising TS 3/4.1.3.1, Reactivity Control Sys. ML17291A4201994-09-26026 September 1994 Suppl to 930709 Application for Amend to License NPF-21 Re Increase in Power Operation,Changing Power/Flow Maps in TS 3/4.2.6,3/4.2.7,3/4.2.8 & 3/4.4.1 & Bases to Reflect Use of Siemens Power Corp Staif Code for Stability Analysis ML17291A3941994-09-18018 September 1994 Application for Amend to License NPF-21,changing TS Table 3.6.3-1 Re Primary Containment Isolation Valve Requirements ML17291A3171994-08-0808 August 1994 Application for Amend to License NPF-21,amending TS 4.0.5, Surveillance Requirements for Inservice Insp & Testing Program. ML17291A2151994-07-12012 July 1994 Application for Amend to License NPF-21,requesting Amend to Ts,Relocating TS Table for Instrument Response Time Limits ML17291A2201994-07-0808 July 1994 Application for Amend to License NPF-21,revising TS W/Regard to Control Rod Scram Insertion Testing Under Emergency Circumstances ML17290B1711994-05-0606 May 1994 Application for Amend to License NPF-21,revising TSs 3/4.3.7.5,3/4.4.2 & 3/4.5.1 for Main Steam Relief Valve Position Indication ML17290B1551994-05-0505 May 1994 Application for Amend to License NPF-21,requesting Mod of Three Equipment Piece Numbers Included in Table 3.6.3-1, Primary Containment Isolation Valves. ML17290A9631994-02-17017 February 1994 Application for Amend to License NPF-21,revising TS to Support Hydrostatic Testing ML17290A9601994-02-17017 February 1994 Application for Amend to License NPF-21,revising TS Section 6.0, Administrative Controls, Including Changing Reporting Relationship for QA Functions in Section 6.2.1.e of TS from Managing Director to Assistant Managing Director,Operations ML17290A9551994-02-0808 February 1994 Application for Amend to License NPF-21,consisting of Changes to TS Table 3.6.3-1,for RCIC-V-8,increasing Stroke Time from 13 Seconds to 26 Seconds & Deleting Note (J) Reference from RCIC-V-8 & RCIC-V-63 ML17290A9031994-01-13013 January 1994 Application for Amend to License NPF-21,requesting Continued Plant Operation W/Eccs Functional,But Not in Strict Compliance W/Requirements for Demonstrating That Response Time within Limits of TS 3/4.3.3, ECCS Instrumentation. ML17290A8961994-01-0606 January 1994 Application for Amend to License NPF-21,requesting Changes to TS to Clarify Instrumentation Testing Requirements ML17290A8781994-01-0606 January 1994 Application for Amend to License NPF-21,requesting Rev to TS to Relocate Requirements for Seismic Monitoring Instrumentation to FSAR & Plant Procedures ML17290A8921994-01-0606 January 1994 Suppl to 930709 Application for Amend to License NPF-21, Increasing Licensed Power Level from 3,323 Mwt to 3,486 Mwt W/Extended Load Line Limit & Changing SRV Setpoint Tolerance to Include Changes to TS Paragraph 6.9.3.2 ML17290A8391993-12-20020 December 1993 Application for Amend to License NPF-21,revising TS 3/4.6.1.8, Drywell & Suppression Chamber Purge Sys. ML17290A8181993-12-0606 December 1993 Application for Amend to License NPF-21,requesting TS Surveillance Requirement 4.6.6.1.b.3 Be Revised to Provide Appropriate Acceptance Criteria for Demonstrating Operability of Primary Containment Hydrogen Recombiner Sys ML17290A8221993-12-0606 December 1993 Application for Amend to License NPF-21,adding Footnote to TS Table 4.3.7.5-1, Accident Monitoring Instrumentation Srs, Exempting Channel Calibr of Safety/Relief Valve Position Indicators from Spec 4.0.4 for 24 H 1999-07-29
[Table view] |
Text
ACCELERATED D " RIBUTION DEMON< RATION SYSTEM REGULATQ INFORMATION DISTRIBUTION STEM (RIDS)
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ACCESSION NBR:920'P140105 DOC. DATE: 92/09/02 NOTARXZED: YES DOCKET 0 FACXL: 50-397 MPPSS Nuclear Pro Jecti Unit 2i Mashington Public Poee 05000397 AUTH. NANE AUTHOR AFFILIATION SORENSENi G. C. 4lashing ton Public Power Supply System REC I P. NANE RECXP XENT AFFILXATXON Document Control Branch (Document Control Desk)
SUBJECT:
Application For amend to License NPF-21> changing TS 3/4. 3. 7. 6 re source range monitor surveillance criteria specified in LCO to incorporate guidance in Rev 1 of GE svc info ltr covering channel rate count.
DISTRIBUTION CODE: AOOID TITLE: OR COPIES'ECEIVED! LTR Submittal: General Distribution
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D NOTES:
RECIPIENT COPIES RECZPZENT COPIES
'ID CODE/NANE LTTR ENCL ID CODE/NANE LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 DEAN> M. 2 2 INTERNAL: ACRS 6 6 NRR/DET'/ESGB 1 NRR/DOEA/OTSB11. 1 1 NRR/DST/SELB,7E'RR/DST/SRXB 1 1 NRR/DST/SICBSH7 1 1 1 1 NUDOCS-ABSTRACT 1 1 8E'C/LF 1 0 OGC/HDS1 1 0 01 1 1 RES/DS IR/EI8 1 1 EXTERNAL:. NRC PDR NSIC S
NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 20
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Bm968 ~ 3000George Wasbtngton Way ~ Rtcbland, Wasbtngton 99352C968 ~ (509)372-5000 September 2, 1992 G02-92-208 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
WNP-2, OPERATING LICENSE NPF-21 RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.3.7.6 SOURCE RANGE MONITORS
Reference:
- 1) General Electric Service Information Letter No. 478, "SRH Minimum Count Rate," dated December 16, 1988
- 2) Letter G02-92-016, dated January 21, 1992, GC Sorensen (SS) to NRC, "Request for Amendment to TS Limiting Condition for Operability 3/4.9.2 Source Range Monitor Operability, Re-fueling Operations"
- 3) Letter, dated April 10, 1992, WH Dean (NRC) to GC Sorensen (SS), "Issuance of Amendment for the Washington Public Power Supply System Nuclear Project No. 2 (TAC No. H82662)"
In accordance with the Code of Federal Regulations, Title 10 Parts 50.90 and
- 2. 101, the Supply System hereby submits a request for amendment to the WNP-2 Technical Specifications. This proposal requests that source range monitor (SRM) surveillance criteria specified in the subject Limiting Condition for Operation be changed (as attached) to incorporate the Reference 1 Service Information Letter (SIL) guidance. The SIL guidance modifies the acceptable SRH channel count rate and signal-to-noise ratio values to maintain the General Electric design confidence level.
This same change was requested in Reference 2. However because the primary purpose of Reference 2 was to request changes in the Refueling Instrumentation Technical Specification SRM requirements to allow a complete core offload the applicability of the SIL guidance to Specification 3/4.3.7.6 was not recognized.
9209140105 92pgp2 PDR ADOCK 05000397 P
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I Page 2 RE(UEST FOR AMEND. TO TS LCO 3/4.3.7.6 SOURCE RANGE MONITORS The SRHs provide the operator with information relative to the neutron level at very low flux levels. As such, the SRH indication is used to determine the approach to criticality and when criticality is achieved. The SRHs provide monitoring of reactivity changes during fuel or control rod movement and give the control room operator early indication of unexpected subcritical multiplication that could be indicative of an approach to criticality. Although no credit is taken for SRM function in any WNP-2 design basis accident or transient analysis they do provide indication to the operator that aids in reactor control.
The Reference I SIL provides guidan'ce to modify the SRH count rate to ensure that the design 95% confidence level is maintained in verifying SRH operability. As stated in the SIL, the acceptable SRH count rate value based on signal-to-noise (S/N) ratio has not been consistent within the BWR community. As a result of inquiries from some BWRs, General Electric conducted studies showing that a 95%
confidence level can be preserved by specifying either 0.7 counts per second (cps) with a- S/N > 20 or 3 cps with a S/N > 2. As stated above, Reference 2 requested this change for Technical Specification 3/4.9.2 (Refueling Operations).
Reference 3 issued the change for implementation at WNP-2. The change is also appropriate for Specification 3/4.3.7.6.
The Supply System has evaluated this change request per 10 CFR 50.92 and determined that it does not represent a significant hazards consideration because it does not:
I) Involve a significant increase in the probability or consequences of an accident previously evaluated. The SRH instrumentation is not assumed to be an initiator of any analyzed event. The SRH instrumentation provides monitoring of neutron flux levels to give the control room operator early indication of unexpected subcritical multiplication that could be indicative of an approach to criticality. As such, action could be taken on the indication to avert or minimize the consequences of the event.
However, the SRH function is not relied upon in any design bases or transient analysis. Rod motion interlocks and other instrumentation are relied on in the accident analysis to avert an accident. The change in acceptable count rate and signal-to-noise ratio preserves the confidence level of the General Electric design. As a result, the consequences of any analyzed events are unaffected because the change does not alter any system or component design assumptions or operation. Therefore, no significant increase in the probability or consequences of an accident previously evaluated will be involved.
- 2) Create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed change in SRH count rate and S/N ratio values does not create the possibility of a new or different kind of accident from any previously evaluated because it does not change modes of plant operation or require physical modifications. The change preserves the original General Electric design confidence level. No new or different kind of accident is therefore credible.
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Page 3 RE(VEST FOR AHEND. TO TS LCO 3/4.3.7.6 SOURCE RANGE HONITORS
- 3) Involve a significant reduction in a margin of safety. The change in SRH count rate and S/N ratio values does not affect a margin of safety because the values preserve the original General Electric design confidence level.
Therefore, no margin of safety is impacted by this change.
As discussed above, the Supply System concludes that this change does not involve a significant hazards consideration, nor is there a potential for significant change in the types or significant increase in the amount of any effluents that may be released offsite, nor does the change involve a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(C)(9) and therefore, per 10 CFR 51.22(b), an environmental assessment of these changes is not required.
This Technical Specification change request has been reviewed and approved by the WNP-2 Plant Operations Committee and the Supply System Corporate Nuclear Safety Review Board. In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.
Very truly yours,
-Q/
G. C. So ensen, Hanager Regulatory Programs (Hail Drop 280)
PLP/bk Attachments cc: RG Waldo - EFSEC JB Hartin - NRC RV NS Reynolds - Winston S. Strawn RR Assa - NRC DL Williams - BPA/399 NRC Site Inspector - 901A
STATE OF WASHINGTON)
Subject:
Request for Amend to TS
) Source Ran e Monitors 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 the 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 1992 G. C. Sodensen, Manager Regulatory Programs On this date personally appeared before me G. C. SORENSEN, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned.
GIVEN under my hand and seal this ~day of 1992.
No u ic in and for the STATE OF WASHINGTON Residing at Kennewick Washin ton My Commission Expires A ril 28 1994
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