NPL-97-0348, Forwards Summary of Revised or Clarified Restart Issues to Be Taken Prior to Restart of Unit 2

Forwards Summary of Revised or Clarified Restart Issues to Be Taken Prior to Restart of Unit 2

ML20140H707
Person / Time
Site:	Point Beach
Issue date:	06/13/1997
From:	Patulski S WISCONSIN ELECTRIC POWER CO.
To:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NPL-97-0348, NPL-97-348, NUDOCS 9706180426
Download: ML20140H707 (8)

Text

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Wisconsin

' Electnc POWER COMPANY Point Beach Nuclear Plant (414) 755 2321 6610 Nuclear Rd., Two Rivers. WI 5424I NPL 97-0348 June 13,1997 Mr. A. Bill Beach Regional Administrator Region III US NUCLEAR REGULATORY COMMISSION 801 Warrenville Road Lisle, IL 60532-4351

Dear Mr. Beach:

DOCKET 50-301 RESTART ISSUES UPDATE POINT BEACH NUCLEAR PLANT. UNIT 2 In our letter dated December 12,1996, we provided you a list ofissues for resolution and other actions to be taken prior to the restart of our Point Beach Nuclear Plant, Unit 2. The list contained a description of eighty-one specific istaes for resolution or action. We committed to j routinely update you and your staff on our progress and any necessary changes to the restart list. I A summary of our progress and status on these startup issues has been presented to your staff during management meetings conducted between our staffs during the past several months. We have forwarded documentation packages for all completed commitment issues to you following verification of successful issue resolution or action completion.

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i As we continue to manage and disposition these issues in preparation for Unit 2 restart, we have l determined it necessary to revise or clarify some of our original commitments. Attached is a summary of restart issues which we have revised or clarified. The attachment summarizes the original commitment number, the onginal commitment description, the reason for clarification or modification of the commitment, and the modified or clarified commitment description.

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. NPL 97-0348 Page 2 If you or your staff have any questions or require additional information regarding these clarified and modified restart issues, please contact us.

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cott A. Patulski Site Vice President lam Attachment cc: NRC Document Control Desk NRC Resident Inspector NRC Project Manager l

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Point Beach Nuclear Plant Unit 2 Startup Commitment List Summary of Revised Commitments Original Original Commitment Reason for Modification or Clarification Modified /Claritied Commitment Description ofCommitment Commitment Description 10 Number 2 Walkdown all accessible Unit 2 and The intent of our original commitment was to Walkdown all accessible Unit 2 and Common Maintenance Rule complete our walkdowns on the Maintenance Rule Common Maintenance Rule portions of systems for adequate visual portion of the system to ensure the physical systems for adequate visual material -

material condition. configuration meets applicable safety standards, condition.

This is a clarification of our original commitment. -

18 Review outstanding JCOs. Perform At the time this commitment was made, we thought Resolve outstanding JCOs using our operability determinations and that all JCOs would be replaced with 10 CFR 50.59 operability determination process and/or 10 CFR 50.59 evaluations needed safety evaluations; however, some JCOs were our 10 CFR 50.59 evaluation process.

to address the issues, resolved via the operability determination process.

22 All open operability evaluations for Since making this commitment, we have All open condition reports for Unit 2 and Unit 2 and common equipment will incorporated new industry practices for evaluating common equipment will be evaluated be reviewed for acceptable closure open issues to determine whether they will impact for their impact on unit restart. Any of the degrade i equipment issue. unit restart. This process involves open issue equipment operability concerns will Disposition outstanding issues in review by our System Engineering Review Board either be corrected or evaluated for accordance with 10 CFR 50.59 and and our Outage Review Committee. All open operability for continued operation in Generic Letter 91-18. condition reports, which include operability accordance with our Operability ,

determinations, fall within the scope of review by - Determination procedure and Generic these committees. Letter 91-18. Equipment which is operable but either degraded or nonconforming will be identified and tracked within our corrective action program to ensure timely correction of these issues.

29 Complete a 10 CFR 50.59 During our work to resolve this issue, we have Original Commitment is withdrawn. ,

evaluation for the existing CCW reviewed our 1992 basis for the classification of supply to the RCP seals as a safety this function. We believe that classification was function. overly conservative. The function should not have been classified as safety-related. The rationale to  ;

classify this function as safety-related was made to address the concern that a small break LOCA could i Page1

Point Beach Nuclear Plant Unit 2 Startup Commitment List Summary of Revised Commitments Original Original Commitment Reason for Modification or Clarification Modified / Clarified Commitment Description ofCommitment Commitment Description ID Number occur due to reactor coolant pump seal failure following a sustained loss of coolant to the seals. It '

was recognized that a reliable source of reactor coolant pump seal coolant would minimize the probability of seal failure. Based on the original -

design criteria, the inherent strengths of the original design with regard to reactor coolant pump seal cooling, reactor coolant pump seal improvements, and a survey of classification decisions at other PWR facilities of similar vintage, we have determined that classifying this function as safety-related is incorrect.

We will submit a letter to the NRC to retract the commitment to classify CCW supply to the RCP

_j thermal barrier as safety-related, which was made in our December 22,1992 letter.

35 Revise applicable IST program The intent of our original commitment was to Revise applicable IST program documents to prevent equipment ensure that IST equipment being retumed to service documents to require the performance of from being retumed to service following maintenance is capable of perfonning its an operability determination and NRC (declared operable) with vibrations required function. If post-maintenance operability notification prior to returning equipment in the alert range. testing identifies vibration levels greater than to service in the event that equipment in 0.325 ips (the ASME OMb-1989 Part 6 upper the Section XI inservice testing program acceptance limit), an operability determination and have vibration levels greater than NRC notification will be completed prior to 0.325 ips.

returning the equipment to service.

38 Complete modification request The original design change package defined that Complete replacement of 67 of the 90 MR 96-033 that replaces control 67 control power transfonners would be replaced control power transformers identified in power transformers on motor during the current Unit 2 outage, and others would modification request MR 96-033. ).

control centers 2B-32 and 2B-42. be replaced during the maintenance week for the Complete remaining post-maintenance Page 2

Point Beach Nuclear Plant Unit 2 Startup Commitment List Summary of Revised Commitments Original Original Commitment Reason for hiodification or Clarification hiodified/ Clarified Commitment Description ofCommitment Commitment Description ID Number associated component. This is a clarifica: ion of our testing following reactor startup.

original commitment.

44 Complete hiodification Request The intent of hiodification Request 96-065*B was Complete modifications to seismically h1R 96-065'B that seismically to address concerns ofloss of RWST inventory upgrade the Refueling Water Storage upgrades the Refueling Water following a seismic event by changing the system Tank (RWST) recirculation line and Storage Tank (RWST) recirculation to comply with FSAR Appendix A requirements. administratively control the manual line. MR 96-065*B was initially scoped to replace the isolation valves nomially closed.

Unit 2 manual isolation valve with an air operated valve capable of remote operation from the control room, and upgrade piping between the RWST header and the AOV to seismic class I. Continued review of this issue canceled the AOV portion of the modification.

To comply with the FSAR Appendix A requirem:nts and address the concerns regarding loss of RWST inventory , we have upgraded the 2-inch piping between the RWST 10-inch header and the manual isolation valves (ISF-820 and 2SF-820B) to seismic Class I. We are administratively maintaining the manual isolation valves in the normally closed position.

53 Complete modification request Additional post-maintenance testing for this Complete the physical work associated MR 94-095 that replaces eight main modihcation will be completed following reactor with modification request MR 94-095 steam condenser steam dump startup, as it requires steam to conduct the testing. that replaces eight main steam condenser valves with improved design. The physical work associated with the modification steam dump valves with an improved will be completed prior to reactor startup. design. Complete remaining post-maintenance testing following reactor startup and completion of fuel conditioning.

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Point lleach Nuclear Plant Unit 2 Startup Commitment List Summary of Revised Commitments Original Original Commitment i Reason ihr Modification or Clarification Modified / Clarified Commitment Description ofCommitment Commitment Description ID Number 56 Complete modification request Additional post-maintenance testing (br this Complete the physical work associated MR 96-063 that replaces 345 kV modification will be completed following reactor with modification request MR 96-063 breakers (3-4,4-5 and 142). startup, because it involves relay checks with the that replaces 345kV breakers (3-4,4-5, '

generator breaker closed and energized. The and 142). Complete remaining post-physical work associated with the modification will maintenance testing following reactor be completed prior to reactor startup. startup.

64 Complete Work Orders 9611624, The work order numbers were incorrectly identified Complete the physical work associated 9611625, and 9611626 that replace in the original commitment. The correct numbers with Work Orders 9611979,9611981, existing pneumatic turbine are Work Orders 9611979,9611981 and 9611982. and 9611982 that replace existing generator circuitry time delay relays Additional post- maintenance testing for this pneumatic turbine generator circuitry with plug-in, electronic time delay modification will be completed fbliowing reactor time delay relays with plug-in, electronic relays. startup, while the physical work will be completed time delay relays. Complete remaining prior to reactor startup. post-maintenance testing fbilowing g reactor startup.

68 Repair valve AR-3511 per Work Additional post-maintenance testing for this Complete the physical work on the Order 95-13340. The Unit 2 modification will be completed following reactor repair of valve AR-3511 per Work priming air ejector is blank flanged startup, as it requires steam to conduct a general Order 95-13340. The Unit 2 priming air due to air in-leakage through the leak test. The physical work associated with the ejector is blanked flanged due to air in-condenser air removal isolation modification will be completed prior to reactor leakage through the condenser air valve, AR-3511. startup. removal isolation valve, AR-3511.

Complete remaining post-maintenance testing fbilowing reactor startup.

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Point Beach Nuclear Plant Unit 2 Startup Commitment List Summary of Revised Commitments Original Original Commitment Reason for hiodification or Clarification Modified / Clarified Commitment Description ofCommitment Commitment Description ID Number 69 Repair the drain valve for the The work order number was incorrectly identif ed Complete the physical work to repair th7 heating steam moisture separator in the original commitment. The correct work drain valve for the heating steam per Work Order 9613451. The ,

,rder for this activity is WO 9607489. meisture separator per Work [

Unit 2 heating steam moisture Order 9607489. The Unit 2 heating separator level has been dillicult to steam moisture separator level has been-maintain during normal operations, difficult to maintain during nonnal and frequent alarms were received operations, and frequent alarms were due to low level. This will be received due to low level. Complete tested following Unit 2 startup. remaining post-maintenance testing following reactor startup.

71 Repair MS-249, the Unit 2 steam Additional post-maintenance testing for this Complete the physical work to repair line sample valve, per Work modification will be completed fbilowing reactor MS-249, the Unit 2 steam line sample Order 9603128. The va'e had a startup, as it requires steam to conduct a general valve, per Work Order 9603128. The packing leak which required steam leak test. The physical work associated with the valve had a packing leak that required header sampling to be shifted to the modification will be completed prior to reactor steam header sampling to be shifted to "B" steam header. startup. the "B" steam header. Complete remaining post-maintenance testing following reactor startup.

72 Repair alarm switch 2LS-2511 per Additional post-maintenance testing for this Complete the physical work to repair Work Order 9605711. The Unit 2 D modification involves a leak test at-power. The alann switch,21.S-2511 per Work MSR level was being maintained physical work associated with this modification Order 9605711. The Unit 2 D MSR low in the band due to level will be completed prior to reactor startup. level was being maintained low in the oscillations and a steam leak from band due to level oscillations and a the alarm switch. steam leak from the alann switch.

Complete remaining post-maintenance testing fbliowing reactor startup.

73 Repair 2P-116, the Unit 2 boric Our original intent was to replace the Unit 2 boric Replace the seals on 2P 116, the Unit 2 acid recirculation pump, per Work acid recirculation pump during the Umt 2 outage boric acid recirculation pump.

Order 9603130. It has a significa,t per Work Order 9603130. To reso!ve this seal seal leak. leakage issue, we are replacing the pump seals.

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Point Beach Nuclear Plant Unit 2 Startup Commitment List Summary of Revised Commitments -

Original Original Commitment Reason for Modification or Cleification Modified / Clarified Commitment Description ofCommitment Commitment Description ID Number 7 81 Submit the following requests for . Technical Specification change request for Submit the following requests fo.

license amendments resulting from crossover steam dump operation was submitted license amendments resulting from the  ;

the review of existing Technical on 2/10/97. review of existing Technical l Specification interpretation - . Technical Specification change request related Specification interpretations:

to RWST boron concentration was submitted on  :

. Revise the maximum acceptable 1/16/97 . Revise the maximum acceptable power level when crossover . Technical Specifications change request that power level when crossover steam  ;

steam dumps are inoperable eliminates provisions for single reactor coolant dumps are inoperable (TS 15.3.4.E.)

(TS 15.3.4.E.) pump operation when shutdewn was submitted Remove allowances in

. Revise requirements for offsite on 4/14/97. TS 15.3.1.A.I.a for single reactor i power lines availability to coolant pump operation.  :

address adequacy OtTsite power requirements have been reviewed . Appropriately modify the minimum (TS 15.3.7.A.I.a.) N along with our DCS 3.1.20 and the NRC Safety required boron concentration in the ,

e Remove allowances in Evaluation dated August 29,1983. The SE Refueling Water Storage Tanks.

TS 15.3.1.A.I.a for single evaluated the PBNP onsite distribution system and reactor coolant pump operation. PBNP conformance to GDC-17 for offsite power. Revise DCS 3.1.20 to restrict operation

. Appropriately modify the The present PBNP Specifications are in agreement of a unit with one line supporting that i minimum required boron with the August 29,1983 Safety Evalueon. unit to 50% power.

concentration in the Refueling Therefore, they are acceptable for ensuring two Water Storage Tanks. sources of power to the operating unit (s). Our i

current DCS 3.1.20 is non-conservative in that it

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• allows a switchyard configuration such that a unit operating with one line supporting the full unit output may be operated at 100% power. This is contradictory to the Technical Specifications and ,

bases which would restrict operation of that unit to 50% power.

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