ML17285A829

Application for Amend to License NPF-21,revising Tech Spec 3.4.6.1 & Supporting Bases Resulting from Implementation of Reg Guide 1.99,per Generic Ltr 88-11, NRC Position on Radiation Embrittlement of Reactor Vessel Matls....

ML17285A829
Person / Time
Site:	Columbia
Issue date:	10/27/1989
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17285A830	List: ML17285A829 ML17285A831
References
RTR-REGGD-01.099, RTR-REGGD-1.099 GL-88-11, GO2-89-201, NUDOCS 8911090139
Download: ML17285A829 (7)

Text

ACCELERATED ATTRIBUTION DEMON~TION SYSTEM

.op REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8911090139 DOC.DATE: 89/10/27 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)

SUBJECT:

Application for amend to License NPF-21,revising TS 3.4.6.1 re pressure/temp limits.

DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution II ENCL L SIZE:

NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 SAMWORTH,R 5 5 INTERNAL ACRS 6 6 NRR/DEST/ADS 7E 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 1 1 NRR/DEST/MTB 9H NRR/DOEA/TSB OC/LFMB ll 1 1

1 1

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NRR/DEST/RSB 8E NUDOCS-ABSTRACT OGC/HDS2 1

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0 ILE 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WAS'ONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20N9) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 25

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WASHINGTON PUBLIC POWER SUPPLY SYSTEM F.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 October 27, 1989 G02-89-201 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 AMENDMENT TO TECHNICAL SPECIFICATION PRESSURE/TEMPERATURE LIMITS - SECTION 3.4.6.1

Reference:

Generic Letter 88-11, "NRC Position on Radiation Embrittlement of Reactor Vessel Materials and its Impact on Plant Operations", dated July 12, 1988 In accordance with the Code of Federal Regulations Title 10, Parts 50.90 and

2. 101, the Supply System hereby requests an amendment to Section 3.4.6. 1 of the Technical Specifications. Specifically, the Supply System is submitting changes to the technical specification and supporting bases resulting from the implementation of Regulatory'uide 1.99, "Radiation Embrittlement of Reactor Vessel Materials", Revision 2, methodologies as directed by the referenced generic letter . The generic letter directs licensees to complete technical analysis using methods described in the recently revised Regulatory Guide to ensure continued compliance with the requirements of Section V of 10CFR Part 50, Appendix G. Accordingly the Supply System has completed the technical analysis and the attached technical specification and bases changes result from that analysis and are required to maintain compliance with Appendix G. These changes are being submitted to ensure compliance with the changes promulgated by Revision 2 to Regulatory Guide 1.99.

The attached Figure 3.4.6. 1 in compliance with Title 10 of the Code of Federal Regulations, Part 50, Appendix G and H is submitted to replace the reactor pressure vessel pressure/temperature limit curves represented by Technical Specification Figures 3.4.6. 1-1 and 3.4.6. 1-2. The Supply System is submitting one figure for review. This figure reflects the End-of-Life (EOL) operational limits for WNP-2's reactor pressure vessel. Figure 3.4.6.1-1 is no longer considered applicable since WNP-2 has passed 3 effective full-power years of operation.

8911090239 S91027 PDR ADOCK 05000397

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Page Two

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'REQUEST FOR AMENDMENT TO TS PRESSURE/TEMPERATURE LIMITS SECTION 3.4.6.1 The attached figure has been updated incorporating the requirements of Regulatory Guide 1.99 Revision 2. The new curves on the revised Figure 3.4.6.1 were developed utilizing the revised Regulatory Guide criteria on irradiation damage.

Both the RPV beltline and feedwater nozzle regions were assessed and are reflected in the new curves. Calculations were completed in compliance with SRP 1.70,Section III ASME Code and Summer 1972 Addenda Appendix G and Welding Research Council Bulletin 175. Changes to the text of Specification 3/4.4.6 and the List of Figures have been made to reflect the replacement of Figures 3.4.6.1-1 and 3.4.6. 1-2 by the revised figure now numbered 3.4.6. 1.

As Figure 3.4.6. 1-1 is no longer applicable to WNP-2 its deletion is not addressed in the following no significant hazards analysis.

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.

The proposed amendment reflects shifts in the pressure temperature limit curves to values which are more conservative then those presently in use.

The methodology used to derive these values is recognized by the NRC and Industry as providing acceptable margins. Hence the probability of a previously evaluated accident is not impacted by these changes but remains at an acceptable value. Higher temperature values for corresponding pressures further reduce brittle fracture possibilities. Nor do these changes increase the consequences of an accident in that the pressure temperature shift is well within all equipment operating margins.

2) Create the possibility of a new or different kind of accident from any accident. previously evaluated.

These changes, as described above, are more conservative yet well within any upper bound limit. No new modes of plant operation result from these changes. The only changes will be in operation of the plant within more conservative limits. As such no new or different kind of accident is credible.

3) Involve a significant reduction in a margin of safety.

As described in 1) above these changes reflect the application of methodologies recognized by the NRC and Industry as providing a sufficient margin of safety. The shift in limits is more conservative than values presently in use but within any upper bound limits. Hence no reduction in a margin of safety is credible with the approval of these changes.

Page Three RE(VEST FOR AMENDMENT TO TS PRESSURE/TEMPERATURE LIMITS SECTION 3.4.6. 1 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 cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusions 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 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 10CFR 50.91, the State of Washington has been provided a copy of this letter.

This submittal satisfies the 180 day submittal requirement of the generic letter.

Further, per the generic letter, in order for WNP-2 to remain in compliance with 10CFR Part 50 Appendix G approval of the proposed amendment is required within 2 plant outages of the effective date of Revision 2 to Regulatory Guide 1.99.

Accordingly with the Regulatory Guide effective May 1988 this change must be approved no later than commencement of initial heat up at the end of the WNP-2 1990 refueling outage tentatively scheduled for May 24, 1990.

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

Request for Amend to TS Pressure/

STATE OF WASHINGTON ) Sub>ect. Temperature Limits Section 3.4.6.1

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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 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 Z7 1989 G. C. S RENSEN, Manager Regulatory Programs On this day personally appeared before me G. C. SORENSEN to me known to be the individual the GIVEN same under

<<a who executed my hand and seal ~

the foregoing instrument and acknowledged that he signed as his free act and deed for the uses and purposes herein mentioned.

this day of ,1989.

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