ML17279A838

Application for Temporary Amend to License NPF-21,waiving Limit of 1,500 Lb Max Weight Above Fuel Storage Pool to Allow Erection of Temporary Protective Cover Over Pool.Fee Paid

ML17279A838
Person / Time
Site:	Columbia
Issue date:	02/18/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML17279A839	List: ML17279A838 ML17279A840
References
GO2-88-038, GO2-88-38, TAC-67181, NUDOCS 8802250457
Download: ML17279A838 (9)

Text

ACCESSION NBR FAC IL: 50-397 AUTH.NANE BORENBEN1 G.C REC IP.NAME REGULATO.INFORNATION DISTRIBUTION STEM (RIDS)8802250457 DOC.DATE: 88/02/18 NOTARIZED:

YEB DOCKET I WPPBB Nuclear Pro Jecti Unit 2>Washington Public Poee 05000397 AUTHOR AFFILIATION Washington Public Poeer Supply System RECIPIENT AFFILIATION Document Control Branch (Document Control Desk>

SUBJECT:

Application for temporary amend to License NPF-211eaiving limit of ii 500 lb max weight above fuel storage pool to allow erection of temporary protective cover over pool.Fee paid.DISTRIBUTION CODE: A0010 COPIES RECEIVED: LTR I ENCL t SIZE: TITLE: OR Submittal:

General Distribution

"<OTES'ECIPIENT ID CODE/NANE PD5 LA SANWORTHIR COPIES LTTR ENCL 1 0 1 1 REC IP IENT Io CODE/NANE PD5 PD COP IES LTTR ENCL 5 5 INTERNAL: ARM/DAF/LFNB NRR/DEST/CEBBH7 NRR/DEBT/RSB 8E NRR/RB12 01 ,".XTERNAL: LPDR NSIC 1 0 1 1 1 1 1 1 1 1 1 1 NRR/DEBT/ADB7E4 NRR/DEBT/MTB 9H NRR/DOEA/TSB11F OGC 15-B-18 RES/DE/EIB NRC PDR 1 1 1 1 1 1 0 1 1 1 1 TOTAL NUNBER OF COPIES REQUIRED: LTTR 20 ENCL 17 0 P Washington Public Power Supply System 3000 George Washington Way P.O.Box 968 Richland, Washington 99352-0968 (509)372-5000 G02-88-038 February 18, 1988 Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen:

Subject:

NUCLEAR PLANT NO.2 OPERATING LICENSE NPF-21, RE(}UEST FOR A ONE TINE ONLY TEMPORARY AMENDt'IENT TO TECHNICAL SPECIFICATION 3.9.7 (CRANE TRAVEL-SPENT FUEL STORAGE POOL)UNDER EMERGENCY CIRCUMSTANCES In accordance with the Code of Federal Regulations, Title 10, Parts 50.90, 2.101, and 50.91(a)(5), the Supply System hereby submits a request for amendment to the NNP-2 Technical Specifications on an emergency basis as provided for in the regulations.

Specifically, the Supply System is requesting that the limit of 1500 pounds maximum weight above the fuel storage pool be waived (as attached)to allow erection of a temporary protective cover over the pool.The cover is necessary to facilitate repairs to the roof of the Reactor Service Building damaged in an overpressure transient which relieved, as allowed for in the design, through the roof.On February 14, 1988 while HNP-2 was shut down, inspections of ilestinghouse breakers were being conducted per NRC bulletin 88-01.Hhile restoring power to electrical breakers for the reactor building supply and exhaust fans the air supply fan inadvertently started.The inadvertent, start was compounded by the trip circuitry being inoperable resulting in an overpressurization of the Reactor Building and damage to the roof.The requested temporary change is to allow the fuel storage pool to be protected from inadvertent missiles which might occur during the repair efforts.This request is submitted on a one time only basis for the dur ation of repairs to the roof.4 8802250457 880218.J PDR ADQCK 0500039 P.PDRl,I 4 t P'age Two RE/VEST FOR A ONE TIME ONLY TEMPORARY AMENDMENT TO TS 3.9.7 (CRANE TRAVEL-SPENT FUEL STORAGE POOL)UNDER EMERGENCY CIRCUMSTANCES Absent this request on an emergency basis, undue hardship resulting from delay in returning the plant to power will be experienced.

Present schedules contemplate repair, testing, readiness review, and return to power being completed within two to three weeks.Administration of this request on other than an emergency basis, would delay the construction of the cover and roof repair well beyond that presently anticipated.

Such a delay, in effect a derating, would significantly alter power forecasts for the region.Generation capability for the region is predominately hydroelectric.

Hence replacement power generation is resulting in drawdown of existing reservoirs during ari abnormally low rain/snowfall season.Delay will contribute to lower reservoirs than anticipated in an already marginal year.Obviously this incident could not have been anticipated, hence the submittal of this request under emergency circumstances.

A temporary cover is necessary.

Roof repair plans call for scaffolding to be erected near the fuel storage pool and repair equipment being used on the roof.Hence the possibility of a missile is credible.Absent a cover a missile could be dropped from the roof into the pool damaging a fuel bundle.The maximum credible missile has been identified as a length of scaffolding pipe approximately eight feet long by 2 inches in diameter dropped end on from 50 ft., the height of the roof above the fuel pool.As designed the cover will protect the fuel pool given this missile.It should be noted that a limited number of structural members will be moved above the fuel pool.This movement involves relocating the beams to their original configuration which will require the use of a crane external to the building.Specifically a Manitowoc 4100 Series I crawler crane with high lift tower attachment having a minimum lift capacity of 8600 lbs at the maximum boom extension and a maximum 32,500 lb capacity.In repairing the roof this situation is unavoidable.

In the worst case, up to 3 members weighing approximately 700 pounds each may have to be replaced (W-12 I beams one 27 feet long, two 24 foot lengths).The method of handling these members will result in these members being tethered whenever unbolted from the structure.

Per the guidance of NUREG 0612,"Control of Heavy Loads at Nuclear Power Plants" section 5.1.6, all crane lifting will be done such that the load will not exceed 50K of the rated capacity of the crane and"below the hook" rigging will be redundant.

Furthermore the crane will not be used over safety related equipment until a satisfactory 10 CFR 50.59 evaluation has been completed.

Other hand tools and equipment will be tied off during use over openings in the roof.Administrative controls such as this will ensure no other missiles are credible and that the beams described above do not represent a dr opped object threat.The intent of the bases for this technical specification is I)that no load in excess of the nominal weight of a fuel assembly be dropped thereby releasing activity greater than that assumed in the l!NP-2 safety analysis, and 2)any possible distortion of fuel in the racks due to missile will not result in a critical array.No fuel assemblies are contemplated to be moved during this repair and, with the cover in place and the administrative controls discussed above, no missile will be capable of penetrating into the fuel storage pool causing a critical array.Hence with the cover in place and with the administrative controls discussed above the bases of the technical specification are not challenged.

0 I Page Three RE/VEST FOR A ONE TIME ONLY TEMPORARY AMENDMENT TO TS 3.9.7 (CRANE TRAVEL-SPENT FUEL STORAGE POOL)UNDER EMERGENCY CIRCUMSTANCES As discussed with members of your staff the cover itself will exceed 1500 pounds.Assembled dimensions 38 by 45 feet to cover the pool dimensions of 34 by 40 feet, each of three sections weighing approximately 7 tons.To ensure the bases of the technical specification remains unchallenged dur ing fabrication of the cover the following compensatory measures will be adhered to: The cover will be fabricated in three sections well away from the spent fuel storage pool ensuring that no construction immediately over the pool is allowed.The cover sections will be moved over the pool with the Reactor Building Crane such that the sections overlap both edges of the pool by at least a foot at all times.This will ensure that in the event a section is dropped it will not contact the pool but rest on the edges of the pool.The Reactor Building Crane meets the requirements for a"single failure proof crane" as per NUREG 0612, Appendix C.o The cover sections will be moved across the pool at a height of approximately twenty inches for obstruction clearance.

However, at all times during movement supports will be in place to ensure that the section does.not drop more than approximately six inches and designed so that no par t of the cover section will come in contact with the pool.o The sections will be fastened together beyond the edge of the pool in the overlap area such that no fastening will be done immediately over the pool and no objects dropped into the pool.o The cover will be secured in a manner to assure that it will not shift in a design seismic event.o Disassembly will be conducted in the reverse manner with the same precaution.

Hence with these compensatory measures the intent of the technical specifi-cation bases will be preserved during assembly and disassembly.

The Supply System has evaluated this request per 10 CFR 50.59 and determined that the technical specification change is appropriate.

With respect to 10 CFR 50.92 the Supply System proposes that this request does not represent a significant hazard relative to fuel pool integrity.

Further, the proposed change will not: 1)Involve a significant increase in the probability or consequences of an accident previously evaluated because with the cover in place and the administrative controls imposed on repair tools, equipment and materials no credible missile will be able to penetr ate into the fuel storage pool hence there is no significant increase in the probability or consequences of a previously evaluated accident.Furthermore compensatory actions taken during placement and removal of the cover will ensure that no increases in the probability or consequences of a previously evaluated accident result from the cover.

e t page Four'REQUEST FOR A ONE TIME ONLY TEMPORARY AMENDMENT TO TS 3.9.7 (CRANE TRAVEL-SPENT FUEL STORAGE POOL)UNDER EMERGENCY CIRCUMSTANCES 2)Create the possibility of a new or different kind of accident than previously evaluated because the cover will not impose any new conditions on the fuel storage pool over those presently in effect and the administrative controls on the repair tools, equipment and material will ensure no new accidents due to these objects are credible.3)Involve a significant reduction in a margin of safety because, as discussed above, the intent of the technical specifications bases is preserved.

The cover is designed such.that with administrative controls the maximum credible missile will not penetrate into the fuel pool and compensatory precautions during placement and removal of the cover wi 11 not create a missile hazard of the cover.Additionally administrative controls on the repair tools, equipment and material will ensure that the margin of safety is maintained.

Hence the present margin of safety is not significantly decreased.

As discussed above, the Supply System considers that this change does not involve a significant hazard ds 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 it involve a significant increase in individual or cummulative occupational radiation exposure.Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10CFR 51.22(c)(9) and therefore, per 10CFR 51.22(b), an environmental assessment of the change is not required.This Technical Specification change has been reviewed and approved by the HNP-2 Plant Operations Committee (POC)and the Supply System Corporate Nuclear Safety Review Board (CNSRB).In accordance with 10CFR170.21, an application fee of One hundred fifty dollars ($150.00)accompanies this request.In accordance with 10CFR 50.91, the State of Washington has been provided a copy of this letter.Should you have any questions, please contact Mr.P.L.Powell, Manager, HNP-2 Licensing.

Very truly yours, G.C.Sorensen, Manager Regulatory Programs PLP/bk Attachments cc: C Eschels-EFSEC JB Martin-NRC RV NS Reynolds-BCP8R RB Samworth-NRC DL Hilliams-'BPA/399 NRC Site Inspector-901A STATE OF WASHINGTON

))COUNTY OF BENTON)SubjeCt: e Alur, I~.;C j:~rA~e rcgu~ri$, V',9, 7 I, P.L.POWELL, being duly sworn, subscribe to and say that I am the Manager, HNP-2 Licensing, for the WASHINGTON PUBLIC POHER 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.1988 P.L.POHELL, Manager HNP-2 Licensing On this day personally appeared before me P.L.POHELL 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 ,1988.Notary Pu lic in and for t e State of Washington Residing at 4 l r~J I'l