ML17279A822

Application for Amend to License NPF-21,requesting one-time Only Amend to Tech Spec 3.6.1.8 to Increase Purging Limit of Containment Through Standby Gas Treatment Sys from 90 H to 100 H.Fee Paid

ML17279A822
Person / Time
Site:	Columbia
Issue date:	02/05/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML17279A823	List: ML17279A822 ML17279A824
References
GO2-88-034, GO2-88-34, TAC-67082, NUDOCS 8802190145
Download: ML17279A822 (6)

Text

.) 'ACCElZMTZD ÃSI'REBUTlON DEMONSTR QON SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8802190145 DOC.DATE: 88/02/05 NOTARXZED: NO 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)

SUBJECT:

Application for amend to License NPF-21,recpxesting one-time only amend to Tech Spec 3.6.1.8.

DISTRXBUTION CODE: A001D TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution ENCL ~ SIZE-NOTES:

RECIPIENT COPIES RECIPIENT COPXES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 5 5 SAMWORTH,R 1 1 INTERNAL: ACRS 6 6 ARM/DAF/LFMB 1 0 A NRR/DEST/ADS7E4 1 1 NRR/DEST/CEB8H7 1 1 NRR/DEST/MTB 1 1 NRR/DEST/RSB 1 1 NRR/DOEA/TSB 1 1 NRR/PMAS ILRB 1 1 OGC 15-B-18 1 0 .

~TSE 01 1 1 RES/DE/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 A

TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 23

Washington Public Power Supply System 3000 George Washington Way P.O. Box 966 Richiand, Washington 99352-0968 (509)372-5000 February 5, 1988 G02-88-034 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, REQUEST FOR A ONE TIME ONLY AMENDMENT TO TECHNICAL SPECIFICATION 3.6.1.8 (DRYWELL AND SUPPRESSION CHAMBER PURGE SYSTEM) 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 WNP-2 Technical Specifications on an emergency basis as provided for in the regulations. Specifically, the Supply System is r equesting that the limit for purging of the containment through the Standby Gas Treatment System be increased from 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

The Limiting Condition for Operation in Technical Specification 3.6.1.8 requires that purging through the Standby Gas Treatment System shall be restricted to less than or equal to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days (while in Opera-tional Conditions 1,2 and 3).

On February 4, 1988, a shutdown occurred providing an opportunity to iden-tify and fix leakage within the drywell. Prior to the February 4 shutdown and leakage repair activities, 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> of purging had been accumulated. At that time it was felt that the 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> s would not be exceeded. However, to allow drywell access for identification and repair of leakage, approxi-mately 16 additional hours of purging were performed increasing the total to date to 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br />.

Since the leakage was felt to be a steam leak a decision was made to remain in hot shutdown to provide a higher pressure to more readily identify the leakage. Additionally remaining in hot shutdown avoided an additional thermal cycle on the vessel. The decision to stay in hot shutdown resulted in accumulating mor e purge hours during the maintenance activities than would have been accumulated had the activities been accomplished in cold shutdown.

8802190i45 880205

,PDR"

,ADOCK 05000397 P DCD

Page Two RE/VEST FOR" A ONE TIME ONLY AMENDMENT TO TS 3.6.1.8 (DRYHELL AND SUPPRESSION CHAMBER PURGE SYSTEM) UNDER EMERGENCY CIRCUMSTANCES As a result, 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br /> have been, accumulated for the- current period and there is certainty that the 90 hour"limit will be,'xceeded. Present plans include a drywell entry at higher pressures to ensure that the steam leak repair has been adequate. In order to ensure personnel safety during this follow-up entry, purging will again be required and the 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> limit challenged. The reinerting prior to power operation will require four hours. Further-more the purge system is used approximately two hours per month while the unit is at power to control containment oxygen. Additionally about 5 to 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> of purging will be required to bring the unit to cold shutdown if necessary again. For those reasons it is requested 'that the LCO be changed to allow 100 *hour s of pur ging during the. current period. This request (attached) is submitted on a one time only basis.

The Supply System closely monitors the total hours purged and had recently, prior to the shutdown, made a determination that the remaining 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> (90-70) would be sufficient. The drywell leakage increase and prudent action to repair it during the shutdown could not be anticipated, hence the 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> margin is no longer sufficient. The Supply System had no way of anticipating the increased drywell leakage necessitating extended drywell entries in hot shutdown hence the submittal of this request under emergency circumstances.

Absent this request undue hardship in plant maneuvering limits would be encountered. Greater restrictions in power operation would be imposed.

Cold shutdown would be required to be entered prior to any purging activities. Thereby causing plant shutdown more frequently and sooner than would normally occur and increased unnecessary thermal cycles. Hence an effective derating over the next operating period.

The Supply System considers the requested additional 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to be suffi-cient to allow the planned entry and containment reinerting discussed above, plus approximately two hours per month to limit oxygen concentration per Technical'pecification 3.6.6.2 and allow one more evolution to reach cold shutdown prior to April 9, 1988 at which time the requested one time only request is not required.

Page Three RE()VEST FOR A ONE TIME ONLY AMENDMENT TO TS 3.6.1.8 (DRYklELL AND SUPPRESSION CHAMBER PURGE SYSTEM) UNDER EMERGENCY CIRCUMSTANCES The Supply System has evaluated this amendment per 10 CFR 50.59 and 50.92 and determined that it does not represent an unr eviewed safety question or a significant hazard relative to containment system integrity. Further, the proposed change will not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated. No physical changes are being made to the Plant. Primary containment integrity is maintained by the operable isolation function of che valves and is not affected by this amendment.

The probability of the postulated accident (a LOCA while put ging through Standby Gas Treatment) occurring during the time period that these additional ten (10) hours are granted for is slightly less than the normal probability. The normal probability being 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> in 365 days which equates to 15 hours for the remaining 62 days before the clock, is reset on April 10, 1988. 'he additional'0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> plus the remaining 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> would provide a, total of 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of venting and purging dur ing this 62 'day period.

2) Create the possibility of a new or different kind of accident than previously evaluated because no new designs or plant operating modes or the scope of the LCO are affected by this amendment..

3) Involve a significant reduction in a margin of safety because, as discussed in 1) above, the amendment does not affect primary contain-ment integrity or increase the probability of occurrence.

The Supply System recognizes the concerns presented in Standard Review Plan (SRP) 6. 1.4 and Branch Technical Position CSB 6-4. Since it is requested that only the 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> limit be increased by, in our judgment, an insignifi-cant amount over the 365 day period, the 10 CFR 100 and ESF equipment analysis waived by SRP 6.2.4, Paragraph II.8 continues to apply for the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> limit. It should also be recognized that no purge or venting operation using standby gas treatment is allowed by the technical specifications without both trains being operable per LCO 3/4.11.2.8 and purge system oper ation is further restricted using one train only (LCO 3/4. 11.2.8). This ensures, despite the unlikely event of a LOCA occurring during purging or venting, that an operable standby gas treatment system is available post-LOCA. It is our belief that this requirement (LCO 3/4.11.2.8) formed an essential part of the bases for permitting a limited amount of operating time without the ESF evaluation referred to in SRP 6.2.4.

Page Four REQUEST FOR A ONE TIME ONLY AMENDMENT TO TS 3.6.1.8 (DRYHELL AND SUPPRESSION CHAMBER PURGE SYSTEM) UNDER EMERGENCY CIRCUMSTANCES

'II As discussed above, the Supply System considers 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 it involve a significant increase in individual or cummulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criteria for cate-gorical 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 WNP-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, WNP-2 Licensing.

Very truly yours, J~N=.

G. C. Sorensen, Manager Regulatory Programs PLP/bk Attachments cc: C Eschels - EFSEC JB Martin NRC RV NS Reynolds - BCP8R RB Samworth NRC DL Williams BPA/399 NRC Site Inspector 901A

Drywell and Suppression STATE OF llASHINGTON )

Subject:

Chamber Pur e S stem

)

COUNTY OF BENTON )

I, P. L. POllELL, being dully sworn, subscribe to and say that I am acting for the Manager, Regulatory Programs, for the WASHINGTON PUBLIC POl(ER SUPPLY SYSTEM, the applicant herein; that I have full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information and belief the statements made in it are true.

DATE w s 1988 P. L. PO)ELL, Acting Manager Regulatory Programs On this day personally appeared before me P. L. POilELL 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 P~ day of ,1987.

o.

Notary Pu lic in and or the State of Washington Residing at