ML17289A471: Difference between revisions

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| issue date = 04/10/1992
| issue date = 04/10/1992
| title = Application for Amend to License NPF-21,revising TS 3/4.4.6 Re Pressure/Temp Limits,In Ref to Generic Ltr 91-01, Removal of Schedule for Withdrawal of Reactor Vessel Matl Specimens from Tss.
| title = Application for Amend to License NPF-21,revising TS 3/4.4.6 Re Pressure/Temp Limits,In Ref to Generic Ltr 91-01, Removal of Schedule for Withdrawal of Reactor Vessel Matl Specimens from Tss.
| 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 =  
Line 14: Line 14:
| 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 = Withdrawal
}}
}}


=Text=
=Text=
{{#Wiki_filter:ACCELERATED DI TRIBUTION DEMONSTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9204200095 DOC.DATE: 92/04/10 NOTARIZED:
{{#Wiki_filter:ACCELERATED DI TRIBUTION DEMONSTION                                         SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
YES DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION SORENSEN,G.C.
ACCESSION NBR:9204200095               DOC.DATE: 92/04/10     NOTARIZED: YES         DOCKET FACIL:50-397   WPPSS   Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME           AUTHOR AFFILIATION SORENSEN,G.C.         Washington Public Power Supply System RECIP.NAME             RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)                 R
Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)R  


==SUBJECT:==
==SUBJECT:==
Application for amend to License NPF-2l,revising TS 3/4.4.6 re pressure/temp limits, in ref to Generic Ltr 91-01,"Removal of Schedule for Withdrawal of Reactor Vessel Matl Specimens from TSs." DISTRIBUTION CODE: A008D COPIES RECEIVED:LTR ENCL SIZE: TITLE: OR/Licensing Submittal:
Application for amend to License NPF-2l,revising TS 3/4.4.6 re pressure/temp limits, in ref to Generic Ltr 91-01, "Removal of Schedule for Withdrawal of Reactor Vessel Matl                     D Specimens from TSs."
Reactor Vessel Material Surveillance Re NOTES: ort D RECIPIENT ID CODE/NAME PD5 LA ENG,P.L.INTERNAL: ACRS NRR/DET/ECMB 9H NRR/DOEA/OTSB11 NRR/DST/SRXB 8E 0 FMB EG 01 CBBMEB EXTERNAL EGGG NAGATA i P~NSIC COPIES LTTR ENCL 1 0 2 2 6 6 1 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD5 PD NRR/DEST/MTB 9H NRR/DET/ESGB 8D NRR/DST 8E2 NRR/PMAS/ILRB12 OGC/HDS1 RES/DSIR/EIB NRC PDR ORNL KAM,F COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 0 1 1 1 1 1 1 D D D NOTE TO ALL"RIDS" RECIPIENTS:
DISTRIBUTION CODE: A008D COPIES RECEIVED:LTR                   ENCL       SIZE:
PLEASE HELP US TO REDUCE WASI'E!CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 23 A D D l
TITLE: OR/Licensing Submittal: Reactor Vessel Material Surveillance                 Re ort NOTES:
sz WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Bm96'8~3000George Wasbtngton Way~Rtcbiand, Washington 99352-0968
RECIPIENT              COPIES            RECIPIENT           COPIES ID   CODE/NAME           LTTR ENCL      ID  CODE/NAME      LTTR ENCL        D PD5 LA                         1    0    PD5 PD                  1    1 ENG,P.L.                     2      2                                            D INTERNAL: ACRS                           6    6    NRR/DEST/MTB 9H         1    1 NRR/DET/ECMB 9H                1    1    NRR/DET/ESGB 8D        1     1 NRR/DOEA/OTSB11                1    1    NRR/DST 8E2            1    1 NRR/DST/SRXB 8E                1    1    NRR/PMAS/ILRB12         1    1 0    FMB                      1    0    OGC/HDS1               1    0 EG              01        1      1    RES/DSIR/EIB           1     1 CBBMEB                      1     1 EXTERNAL  EGGG NAGATAi P    ~          1     1     NRC PDR                1     1 NSIC                          1     1     ORNL KAM,F              1     1 D
~(509)372-5000 April 10, 1992 G02-92-087 Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555  
A D
D NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASI'E! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR               26   ENCL   23
 
l sz WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Bm96'8 ~ 3000George Wasbtngton Way ~ Rtcbiand, Washington 99352-0968 ~ (509)372-5000 April 10, 1992 G02-92-087 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn:   Document Control Desk Washington, D.C.       20555


==Subject:==
==Subject:==
WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.4.6    PRESSURE/TEMPERATURE        LIMITS


==Reference:==
==Reference:==
Generic Letter, 91-01, "Removal of the Schedule for the Withdrawal of Reactor Vessel Haterial Specimens from the Technical Specifica-tions", dated January 4, 1991 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 the schedule for the withdrawal of reactor vessel material specimens be removed from Technical Specification 3/4.4.6 as suggested by the referenced letter.
As  required by Appendix H to 10 CFR Part 50, specimens of reactor vessel material are  installed near the inside reactor vessel wall and are withdrawn on a schedule to provide data as to the effect of radiation and thermal environment on the vessel material.          Using this data the pressure/temperature                    limits curve (Technical Specification Figure 3.4.6. 1) is adjusted, as necessary, to compensate for the shift in material transition temperature as indicated by tests of the withdrawn specimens. The withdrawal and analysis of the specimens and resulting revision of the pressure/temperature limits curve compose the program necessary to ensure that WNP-2 is operated with confidence in the ductility region of the vessel material. Exposure to a potential for brittle fracture is then precluded.
Section II.B.3 of Appendix H to 10 CFR Part 50 requires the submittal to, and approval by, the NRC of a specimen withdrawal schedule prior to program implementation. WNP-2 Final Safety Analysis Report Section 5.3. 1.6. 1 describes the withdrawal schedule which was approved by the NRC in NUREG-0892, the WNP-2 Safety Evaluation Report. As noted in the reference, having the withdrawal schedule in the Technical Specifications duplicates the controls established by Appendix H. Hence, deletion of the schedule, as suggested, is appropriate and does not decrease        the clarity of the requirement or represent a loss of regulatory control.          Accordingly, this letter follows the guidance of the reference and requests removal of the schedule.
th 9204200095 '720410 PDR    ADOCK 05000397 P                      PDR


WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.4.6 PRESSURE/TEMPERATURE LIMITS Generic Letter, 91-01,"Removal of the Schedule for the Withdrawal of Reactor Vessel Haterial Specimens from the Technical Specifica-tions", dated January 4, 1991 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.
Page Two RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.4.6,   PRESSURE/TEMPERATURE     LIMITS The attached Technical     Specification pages indicate the changes as suggested by the enclosure to the reference.         Table 4.4.6. 1.3. 1, "Reactor Vessel Material Surveillance Program Withdrawal Schedule" has been deleted, Surveillance Requirement 4.4.6. 1.3 has been modified to delete reference to the removed table and the "List of Tables", page xxiv, also shows deletion of the table.             As recommended by the reference the requirement to update the pressure/temperature curves as a result of the specimen examination has been retained in Surveillance Requirement 4.4.6. 1.3. The reference also required a commitment to include the withdrawal schedule in the next revision of the safety analysis report and commit to maintaining   it in the safety analysis report. As noted above, the schedule is in the WNP-2 FSAR. Further,       it will be updated, to reflect the details of the removed schedule, in the next revision of the FSAR and retained in the FSAR as part of the Appendix H compliance description.
This proposal requests that the schedule for the withdrawal of reactor vessel material specimens be removed from Technical Specification 3/4.4.6 as suggested by the referenced letter.As required by Appendix H to 10 CFR Part 50, specimens of reactor vessel material are installed near the inside reactor vessel wall and are withdrawn on a schedule to provide data as to the effect of radiation and thermal environment on the vessel material.Using this data the pressure/temperature limits curve (Technical Specification Figure 3.4.6.1)is adjusted, as necessary, to compensate for the shift in material transition temperature as indicated by tests of the withdrawn specimens.
The Supply System     has evaluated this amendment request per 10CFR 50.92 and determined that   it does   not represent a significant hazard because   it does not:
The withdrawal and analysis of the specimens and resulting revision of the pressure/temperature limits curve compose the program necessary to ensure that WNP-2 is operated with confidence in the ductility region of the vessel material.Exposure to a potential for brittle fracture is then precluded.
: 1)     Involve a significant increase in the probability or consequences of an accident previously evaluated because the regulatory requirement of 10 CFR 50 Appendix H will remain in effect in the Technical Specifications.
Section II.B.3 of Appendix H to 10 CFR Part 50 requires the submittal to, and approval by, the NRC of a specimen withdrawal schedule prior to program implementation.
Removing Table 4.4.6. 1.3-1, and any references to it, will not result in any loss of regulatory control because changes to this schedule are controlled by the requirements of 10 CFR 50 Appendix H. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
WNP-2 Final Safety Analysis Report Section 5.3.1.6.1 describes the withdrawal schedule which was approved by the NRC in NUREG-0892, the WNP-2 Safety Evaluation Report.As noted in the reference, having the withdrawal schedule in the Technical Specifications duplicates the controls established by Appendix H.Hence, deletion of the schedule, as suggested, is appropriate and does not decrease the clarity of the requirement or represent a loss of regulatory control.Accordingly, this letter follows the guidance of the reference and requests removal of the schedule.th 9204200095
: 2)     Create the   possibility of a new or different kind of accident from any accident previously evaluated because as previously stated in Appendix H Section II.B.3 of 10 CFR 50, the licensee must have a withdrawal schedule approved by the NRC prior to program implementation.         Removal of Table 4.4.6. 1.3-1 and any references to       it only eliminates duplication of a requirement that is already adhered to by compliance to 10 CFR 50 Appendix H, No new modes of operation of any equipment result due to this change. Therefore this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
'720410 PDR ADOCK 05000397 P PDR Page Two RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.4.6, PRESSURE/TEMPERATURE LIMITS The attached Technical Specification pages indicate the changes as suggested by the enclosure to the reference.
: 3)     Involve   a   significant reduction in     a margin   of safety because the surveillance     requirement   still requires   surveillance specimens to be removed and examined, to determine changes in material properties, at intervals required by 10 CFR 50 Appendix H. Further, no change is made in the requirement that the results of these examinations shall be used to update the pressure/temperature curves of Technical Specification Figure 3 '.6. 1. Therefore, this change does not involve a significant reduction in a margin of safety. '
Table 4.4.6.1.3.1,"Reactor Vessel Material Surveillance Program Withdrawal Schedule" has been deleted, Surveillance Requirement 4.4.6.1.3 has been modified to delete reference to the removed table and the"List of Tables", page xxiv, also shows deletion of the table.As recommended by the reference the requirement to update the pressure/temperature curves as a result of the specimen examination has been retained in Surveillance Requirement 4.4.6.1.3.The reference also required a commitment to include the withdrawal schedule in the next revision of the safety analysis report and commit to maintaining it in the safety analysis report.As noted above, the schedule is in the WNP-2 FSAR.Further, it will be updated, to reflect the details of the removed schedule, in the next revision of the FSAR and retained in the FSAR as part of the Appendix H compliance description.
The Supply System has evaluated this amendment request per 10CFR 50.92 and determined that it does not represent a significant hazard because it does not: 1)Involve a significant increase in the probability or consequences of an accident previously evaluated because the regulatory requirement of 10 CFR 50 Appendix H will remain in effect in the Technical Specifications.
Removing Table 4.4.6.1.3-1, and any references to it, will not result in any loss of regulatory control because changes to this schedule are controlled by the requirements of 10 CFR 50 Appendix H.Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2)Create the possibility of a new or different kind of accident from any accident previously evaluated because as previously stated in Appendix H Section II.B.3 of 10 CFR 50, the licensee must have a withdrawal schedule approved by the NRC prior to program implementation.
Removal of Table 4.4.6.1.3-1 and any references to it only eliminates duplication of a requirement that is already adhered to by compliance to 10 CFR 50 Appendix H, No new modes of operation of any equipment result due to this change.Therefore this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3)Involve a significant reduction in a margin of safety because the surveillance requirement still requires surveillance specimens to be removed and examined, to determine changes in material properties, at intervals required by 10 CFR 50 Appendix H.Further, no change is made in the requirement that the results of these examinations shall be used to update the pressure/temperature curves of Technical Specification Figure 3'.6.1.Therefore, this change does not involve a significant reduction in a margin of safety.'  


t Page Three RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.4.6, PRESSURE/TEMPERATURE LIMITS As discussed above, the Supply System considers that these changes do 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 do they involve a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed changes meet 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 (POC)and the Supply System Corporate Nuclear Safety Review Board (CNSRB).In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.Sincerely, G.C.Sorensen, Manager Regulatory Programs (Hail Drop 280)PLP/bI<Attachments cc: RG Waldo-EFSEC JB Hartin-NRC RV NS Reynolds-Winston&Strawn WH Dean-NRC DL Williams-BPA/399 NRC Site Inspector-901A  
Page Three 3/4.4.6, t
RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION PRESSURE/TEMPERATURE   LIMITS As discussed above, the Supply System considers that these changes do 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 do they involve a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet 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 (POC) and the Supply System Corporate Nuclear Safety Review Board (CNSRB). In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.
Sincerely, G. C. Sorensen,   Manager Regulatory Programs (Hail Drop 280)
PLP/bI<
Attachments cc:     RG Waldo - EFSEC JB Hartin -   NRC RV NS Reynolds - Winston & Strawn WH Dean - NRC DL Williams - BPA/399 NRC Site Inspector - 901A


STATE OF WASHINGTON)
STATE OF WASHINGTON)                    
)COUNTY OF BENTON


==Subject:==
==Subject:==
Re uest for Amend to Tech.S ecs.3 4.4.6 Pressure Tem erature Limits I.A.G.HOSLER, being duly sworn, subscribe to and say that I am the'Manager, WNP-2 Licensing 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 A.G.Hosier, Manager WNP-2 Licensing On this date personally appeared before me A.G.HOSLER, 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.
Re   uest for Amend to Tech. S ecs.
BIVEN under my hand and seal this~day of 1992.Notary Public n and for the STATE OF WASHINGTON Residing at Kennewick Washin ton My Commission Expires A ril 28 1994 f 4 ll'}}
                      )                            3 4.4.6 Pressure Tem   erature Limits COUNTY OF BENTON I. A. G. HOSLER, being duly sworn, subscribe       to   and say that I am   the 'Manager, WNP-2   Licensing 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 A. G. Hosier, Manager WNP-2   Licensing On this date personally   appeared before me A. G. HOSLER, 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.
BIVEN under my hand and seal     this ~day           of                               1992.
Notary Public   n   and   for the STATE OF WASHINGTON Residing at     Kennewick   Washin ton My Commission Expires       A ril   28   1994
 
f 4 ll'}}

Latest revision as of 06:41, 10 November 2019

Application for Amend to License NPF-21,revising TS 3/4.4.6 Re Pressure/Temp Limits,In Ref to Generic Ltr 91-01, Removal of Schedule for Withdrawal of Reactor Vessel Matl Specimens from Tss.
ML17289A471
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 04/10/1992
From: Sorensen G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17289A472 List:
References
GL-91-01, GL-91-1, GO2-92-087, GO2-92-87, NUDOCS 9204200095
Download: ML17289A471 (9)


Text

ACCELERATED DI TRIBUTION DEMONSTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9204200095 DOC.DATE: 92/04/10 NOTARIZED: YES DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION SORENSEN,G.C. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) R

SUBJECT:

Application for amend to License NPF-2l,revising TS 3/4.4.6 re pressure/temp limits, in ref to Generic Ltr 91-01, "Removal of Schedule for Withdrawal of Reactor Vessel Matl D Specimens from TSs."

DISTRIBUTION CODE: A008D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR/Licensing Submittal: Reactor Vessel Material Surveillance Re ort NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD5 LA 1 0 PD5 PD 1 1 ENG,P.L. 2 2 D INTERNAL: ACRS 6 6 NRR/DEST/MTB 9H 1 1 NRR/DET/ECMB 9H 1 1 NRR/DET/ESGB 8D 1 1 NRR/DOEA/OTSB11 1 1 NRR/DST 8E2 1 1 NRR/DST/SRXB 8E 1 1 NRR/PMAS/ILRB12 1 1 0 FMB 1 0 OGC/HDS1 1 0 EG 01 1 1 RES/DSIR/EIB 1 1 CBBMEB 1 1 EXTERNAL EGGG NAGATAi P ~ 1 1 NRC PDR 1 1 NSIC 1 1 ORNL KAM,F 1 1 D

A D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASI'E! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 23

l sz WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Bm96'8 ~ 3000George Wasbtngton Way ~ Rtcbiand, Washington 99352-0968 ~ (509)372-5000 April 10, 1992 G02-92-087 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.4.6 PRESSURE/TEMPERATURE LIMITS

Reference:

Generic Letter, 91-01, "Removal of the Schedule for the Withdrawal of Reactor Vessel Haterial Specimens from the Technical Specifica-tions", dated January 4, 1991 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 the schedule for the withdrawal of reactor vessel material specimens be removed from Technical Specification 3/4.4.6 as suggested by the referenced letter.

As required by Appendix H to 10 CFR Part 50, specimens of reactor vessel material are installed near the inside reactor vessel wall and are withdrawn on a schedule to provide data as to the effect of radiation and thermal environment on the vessel material. Using this data the pressure/temperature limits curve (Technical Specification Figure 3.4.6. 1) is adjusted, as necessary, to compensate for the shift in material transition temperature as indicated by tests of the withdrawn specimens. The withdrawal and analysis of the specimens and resulting revision of the pressure/temperature limits curve compose the program necessary to ensure that WNP-2 is operated with confidence in the ductility region of the vessel material. Exposure to a potential for brittle fracture is then precluded.

Section II.B.3 of Appendix H to 10 CFR Part 50 requires the submittal to, and approval by, the NRC of a specimen withdrawal schedule prior to program implementation. WNP-2 Final Safety Analysis Report Section 5.3. 1.6. 1 describes the withdrawal schedule which was approved by the NRC in NUREG-0892, the WNP-2 Safety Evaluation Report. As noted in the reference, having the withdrawal schedule in the Technical Specifications duplicates the controls established by Appendix H. Hence, deletion of the schedule, as suggested, is appropriate and does not decrease the clarity of the requirement or represent a loss of regulatory control. Accordingly, this letter follows the guidance of the reference and requests removal of the schedule.

th 9204200095 '720410 PDR ADOCK 05000397 P PDR

Page Two RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION 3/4.4.6, PRESSURE/TEMPERATURE LIMITS The attached Technical Specification pages indicate the changes as suggested by the enclosure to the reference. Table 4.4.6. 1.3. 1, "Reactor Vessel Material Surveillance Program Withdrawal Schedule" has been deleted, Surveillance Requirement 4.4.6. 1.3 has been modified to delete reference to the removed table and the "List of Tables", page xxiv, also shows deletion of the table. As recommended by the reference the requirement to update the pressure/temperature curves as a result of the specimen examination has been retained in Surveillance Requirement 4.4.6. 1.3. The reference also required a commitment to include the withdrawal schedule in the next revision of the safety analysis report and commit to maintaining it in the safety analysis report. As noted above, the schedule is in the WNP-2 FSAR. Further, it will be updated, to reflect the details of the removed schedule, in the next revision of the FSAR and retained in the FSAR as part of the Appendix H compliance description.

The Supply System has evaluated this amendment request per 10CFR 50.92 and determined that it does not represent a significant hazard because it does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated because the regulatory requirement of 10 CFR 50 Appendix H will remain in effect in the Technical Specifications.

Removing Table 4.4.6. 1.3-1, and any references to it, will not result in any loss of regulatory control because changes to this schedule are controlled by the requirements of 10 CFR 50 Appendix H. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated because as previously stated in Appendix H Section II.B.3 of 10 CFR 50, the licensee must have a withdrawal schedule approved by the NRC prior to program implementation. Removal of Table 4.4.6. 1.3-1 and any references to it only eliminates duplication of a requirement that is already adhered to by compliance to 10 CFR 50 Appendix H, No new modes of operation of any equipment result due to this change. Therefore this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3) Involve a significant reduction in a margin of safety because the surveillance requirement still requires surveillance specimens to be removed and examined, to determine changes in material properties, at intervals required by 10 CFR 50 Appendix H. Further, no change is made in the requirement that the results of these examinations shall be used to update the pressure/temperature curves of Technical Specification Figure 3 '.6. 1. Therefore, this change does not involve a significant reduction in a margin of safety. '

Page Three 3/4.4.6, t

RE(VEST FOR AMENDMENT TO TECHNICAL SPECIFICATION PRESSURE/TEMPERATURE LIMITS As discussed above, the Supply System considers that these changes do 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 do they involve a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet 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 (POC) and the Supply System Corporate Nuclear Safety Review Board (CNSRB). In accordance with 10 CFR 50.91, the State of Washington has been provided a copy of this letter.

Sincerely, G. C. Sorensen, Manager Regulatory Programs (Hail Drop 280)

PLP/bI<

Attachments cc: RG Waldo - EFSEC JB Hartin - NRC RV NS Reynolds - Winston & Strawn WH Dean - NRC DL Williams - BPA/399 NRC Site Inspector - 901A

STATE OF WASHINGTON)

Subject:

Re uest for Amend to Tech. S ecs.

) 3 4.4.6 Pressure Tem erature Limits COUNTY OF BENTON I. A. G. HOSLER, being duly sworn, subscribe to and say that I am the 'Manager, WNP-2 Licensing 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 A. G. Hosier, Manager WNP-2 Licensing On this date personally appeared before me A. G. HOSLER, 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.

BIVEN under my hand and seal this ~day of 1992.

Notary Public n and for the STATE OF WASHINGTON Residing at Kennewick Washin ton My Commission Expires A ril 28 1994

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