ML17285A594

Application for Amend to License NPF-21,modifying Tech Spec Tables 3.3.7.5-1 & 4.3.7.5-1 Re Accident Monitoring Instrumentation & Surveillance Requirements

ML17285A594
Person / Time
Site:	Columbia
Issue date:	06/23/1989
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17285A595	List: ML17285A594 ML17285A596
References
GO2-89-114, NUDOCS 8907060012
Download: ML17285A594 (7)

Text

AC CKLKRATED REGULATO INFORMATION DISTRIBUTION STEM (RIDS)

ACCESSION NBR 8907060012 DOC.DATE: 89/06/'23 NOTARIZED: YES DOCKET I FACIL'.50-~07 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-2l,modifying Table 3.3.7.5-1 to remove Instruments 24 6 29.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR t ENCL / SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 h SAMWORTH,R 5 5 INTERNAL: ACRS 6 6 NRR/DEST/ADS 7E 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/RSB 8E 1 1 NRR/DOEA/TSB 11 1 1 NUDOCS-ABSTRACT 1 1 -

&/Kt 1 0 OGC/HDS2 1 0 REG FILE 01 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 h,

D NOIE 'lO ALL '%IZG" R1XIPI1WIS:

S, PIZASE HELP US TO EKDOCE HASTE QggWCI'HE 1XX:X1M1iÃZ CORI!ROL DES KI BDCN Pl-37 (EXT. 20079) K) 1KXMI2QTE ACR MME HKH DISTRIBUTION LISTS B3R ~2KNXS YOU DGHIT NEED(

l TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 26

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 June 23, 1989 G02-89-114 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington. D.C. 20555 Gentlemen:

Subject:

NUCLfAR PLANT NO. 2 OPERATING LICENSE NPF-21, REQUEST FOR AMENDMENT TO TECHNICAL SPECIFICATION TABLES 3.3.7.5-1 AND 4.3.7.5-1 ACCIDENT MONITORING INSTRUMfNTATION AND SURVEILLANCE REQUIREMENTS POST ACCIDENT SAMPLING SYSTEM (PASS)

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. Specifically, the Supply System is requesting that the subject tables be modified, as attached, to remove instruments No. 24 and

29. These instruments, Post Accident Sampling Containment Atmospheric and Primary Coolant Radiation Monitors are part of the PASS but do not support the bases (section 3/4.3.7.5) of the Accident Monitoring Instrumentation or the dinglyy, function of PASS. The function of the PASS is to provide a method for evalua-ting the extent of core degradation as required by TMI action item II.B.3.

The bases for the Accident Monitoring Instrumentation LCO is to ensure selected parameters necessary to monitor and assess plant conditions following an accident are available. The monitors do not support either bases. Accor-these instruments should be removed from the Technical Specifica-tions.

Presently these monitors, integral to the Post Accident Sample Sink, perform the following functions:

824 Containment Atmospheric Radiation Monitor - "The deposi-tion of iodine is monitored during sampling using a radia-tion detector installed adjacent to the cartridge." (WNP-2 FSAR Appendix B, page B.2-16c).

8907060012 890623 PDR ADQCk 05000397 PNU

Page Two REQUEST FOR AMENDMENT TO TS TABLES 3.3.7.5-1 AND 4.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION 5 SURVEILLANCE RE(}UIREMENTS 829 Primary Coolant Radiation Monitor - "A radiation monitor in the liquid sample enclosure monitors liquid flow from the sample station to provide immediate assessment of the sample activity level. This monitor also provides information as to the effectiveness of the demineralized water flushing of the sample system following sample operation." (WNP-2 FSAR Appendix 8, page 8.2-16a).

Per plant procedures neither monitor:

o provides input to plant actions during or following an accident, nor o contributes to calculations relied upon to determine the extent of core damage post accident. Portable area radiation monitors are used to minimize exposure of personnel during sampling activities.

The Supply System does not intend to remove these instruments from service.

They will be maintained as are other non-safety related instr umentation. The instruments are part of the PASS which is a function required by the Proce-dures and Programs section 6.8.4.c in the Administrative Controls section of the WNP-2 Technical Specifications. The inoperable status of the devices however should not impact plant operation since it is the capability to sample and not the information provided by these instruments that is required.

Although not relied upon as justification for removal, it appears that these instruments may have been added to the WNP-2 Technical Specification in error.

Similar Technical Specifications for LaSalle, Susquehanna, Shoreham, Fermi, Hatch, and Limerick do not contain these instr uments and as such may provide a precedent for their removal.

The Supply System has reviewed the requested amendment and determined that it does not represent a significant hazard because it does not:

I) Involve a significant increase in the probability or consequences of an accident previously evaluated because, as discussed above, the instr u-ments do not provide input to plant actions during or following an acci-dent. As such the removal of these instruments from the Technical Speci-fications will not affect the plant accident response capabilities.

Hence, no increase in the consequences of an accident previously evaluated is considered credible. The PASS and the subject instruments are used post accident but do not provide an automatic mitigation func-tion. The proposed change can therefor e not influence the probability of occurrence of an accident previously evaluated.

Page Three REQUEST FOR AMENDMENT TO TS TABLES 3.3.7.5-1 AND 4.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION & SURVEILLANCE REQURIEMENTS

2) Create the possibility of a new or different kind of accident from any accident previously evaluated because the unavailability of the instru-mentation will not prevent the PASS from performing its design function.

Additionally the proposed change does not represent a change to plant design. Hence no new or different accident possibilities are introduced with this change.

3) Involve a significant reduction in a margin of safety because as dis-cussed above the subject instruments do not contribute to the functional bases of the PASS -and serve no significant function during post accident conditions. Hence no safety margins are reduced by removing them from the Technical Specifications.

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. Accor-dingly, 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 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.

Very truly yours, G. C. orensen, 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

'0 4 ~ ,( II l

J

STATE OF WASHINGTON) Sub ject: ZHC/~%4/mdrru.

)

COUNTY OF BENTON )

7A4Q 3.g 7-5-/

4 Sv. X-]

I, G. C. Sorensen, being duly sworn, subscribe to and say that I am the Manager, Regulatory Programs, for the llASHINGTON PUBLIC POHER SUPPLY SYSTEMa 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 a.id belief the statements made in it are true.

DATE gJdr, 1989

. C. Sy ensen, Manager Regulatory Programs On this day 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.

GIYEN under my hand and seal this ~day of 1989.

otary' ic in and or t e ATE OF lNSHINGTON Residing at My commission expires 1 91 s

p f '

I 1

r

'e"--

rr 'v C @