Text

Application for Amends to Licenses DPR-24 & DPR-27, Incorporating Changes to TSs to More Clearly Define Requirements for Svc Water Sys Operability
	ML20236W776
Person / Time
Site:	Point Beach
Issue date:	07/30/1998
From:	Kaminskas V; WISCONSIN ELECTRIC POWER CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236W777	List: L-98-613, Application for Amends to Licenses DPR-24 & DPR-27, Incorporating Changes to TSs to More Clearly Define Requirements for Svc Water Sys Operability; ML20236W786; NPL-98-0613, Application for Amends to Licenses DPR-24 & DPR-27, Incorporating Changes to TSs to More Clearly Define Requirements for Svc Water Sys Operability;
References
	NPL-98-0613, NPL-98-613, NUDOCS 9808060205
	Download: ML20236W776 (16)
	v • d • e

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l Wisconsin Electnc POWER COMPANY l

Point Beach Nuclear Plant (920) 755-2321 l 6610 Nuclear Rd., Two Rivers. WI 54241 NPL 98-0613 July 30,1998 Document Control Desk U.S. NUCLEAR REGULATORY COMMISSION Mail Station Pl-137 Washington, DC 20555 Ladies / Gentlemen:

l DOCKETS 50-266 AND 50-301 TECHNICAL SPECIFICATIONS CH ANGE REOUEST 206 SERVICE WATER SYSTEM OPERABILITY

POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 In accordance with the requirements of 10 CFR 50.4 and 10 CFR 50.90, Wisconsin Electric l Power Company (licensee) hereby requests amendments to facility operating licenses DPR-24 and DPR-27, for Point Beach Nuclear Plant, Units 1 and 2, respectively. The purpose of the proposed amendments is to incorporate changes to the Technical Specifications to more clearly l define the requirements for Service Water System operability.

i We recently identified that the Service Water (SW) system was not being operated in strict accordance with the system configuration assumed in our SW system analyses. Analyses were performed to support the existing SW Technical Specifications which were approved with Amendments 174 and 178 for Units 1 and 2, respectively, on July 9,1997. Since that time, a number ofinconsistencies between the system mcdel and configuration buve been identified which call into question whether the previous analyses bound system opeistion. Each of these inconsistencies were evaluated and the system detemiined to be operable for the identified concems. l l The most significant of these inconsistencies is an assumption concerning the isolation of l nonessential loads prior to the transfer to containment sump recirculation cooling following a l design basis accident which may not have occurred as assumed by the evaluations. As a result, administrative controls were placed on SW system operation which limits allowed system lineups more restrictively than the present Technical Specifications. }fi ,

Analyses supporting this amendment request were initiated following the identification of the [

inconsistencies. These administrative controls are interim restrictions until these amendments are approved to ensure the Technical Specifications control allowed conditions of the SW kb 9908060205 980730 yDR ADOCK 05000246 PDR -

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1 NPL 98-0613 !

July 30,1998 Page 2 j

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1 system. These administrative controls do not conflict with any Technical Specification and h.tve been evaluated to ensure that the controls do not result in an unreviewed safety question.

Attached are a description of changes, safety evaluation, no significant hazards, and edited Technical Specification and related bases pages supporting the requested changes.

We have determined Chat the proposed amendments do not involve a significant hazards consideration, authorize a significant change in the types or total amounts of effluent release, or result in any significant increase in individual or cumulative occupational radicion exposure.

Therefore, we 'nclude that the proposed amendments meet the categorical eu .usion requirements of 10 CFR 51.22(c)(9) and that an environmental impact appraisal need not be prepared.

Please contact us if you have any questions, or require additional information. i Sincerely, M

Vito A. Kammskas Manager, Subscribed and swom before me on Regulatory Sers ':es & Licensing this J o b day of Quza. ,1998.

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cc: NRC Resident Inspector s'd 8d u dl>

NRC Regional Administrator NdtaryI%lic, State of Wisconsin NRC Project Manager PSCW My commission expires September 16,2001.

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NPL 98-0613 Attachment 1 Page1 DESCRIPTION OF CHANGES TECHNICAL SPECIFICATIONS CHANGE REOUEST 206 SERVICE WATER SYSTEM OPERABILITY POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 Introduction In accordance with the requirements of 10 CFR 50.4 and 10 CFR 50.90, Wisconsin Electric Power Company (licensee) hereby requests amendments to facility operating licenses DPR-24 and DPR-27, for Point Beach Nuclear Plant, Units 1 and 2, respect.fvely.

The purpose of the proposed amendments is to incorporate changes to the Technied Specifications to more clearly define the requirements for Service Water System operability.

Analyses were recently completed to correct inconsistencies between the hydraulic model used by Wisconsin Electric (WE) to demonstrate Service Water (SW) system operability and PBNP procedures which effect system operation. As a result of these new analyses, changes to the Technical Specifications are proposed to ensure the inputs and assumptions to the analyses which demonstrate system operability are appropriately ,

reflected as limiting conditions on system operation. The proposed changes limit allowed service water header configurations and provide clarification of requirements for SW supply to the containment fan coolers. A description of proposed changes and the basis for these changes follows.

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Service Water Header Continuous Flownath Technical Specification 15.3.3.D-2.b provides Limiting Conditions for Operation of the SW flowpath. The Specificati a defines allowed header md related SW pump configurations supported by the analyses and provides for limiting time periods when the system is not fully operable as defined in TS 15.3.3.D-1. The following changes to this Specification are proposed.

b. The service water header continuous flowpath may be out of service for a period of un to 7 days subject to the followine conditions and the limitations of 15.3.3.D-2.a:

i. At least five service water numns are operable.

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ii. If four service water numns are operable. then the flow nath is internmted only between the service water numn havs.

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NPL 98-0613

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l OJ: l iii. Service water numn and continuous flwvpath alienment may be different from that defimed in b.i or b.ii above provided an evaluation is nerformed demonstrating reauired systems are operable nrior to establishing the configuration.

If!ca: than four ser ice veter pe=ps are operab!:, ser ice vcater cy e=

Dev da!! be evaluated inin 21 houm efle:: than fcur service vater pump: Ecing cperable. Ifit is de:enrined th: any equipment suonoded by service water will not receive sufficient flow due to the service water ntige and flownath alienment. then the applicable LCOs for the affected equipment shall be entered and reauired action taken. 'It: LCO: enn be exited if;y ::= realignment is ecmp!:ted 10 cchieve the required Ecv' rate:

for the affected equipment Basis for Chance The PBNP Service Water system consists of two trains of service water pumps (3 pumps per train), feeding a common loop header. Equipment and components supported by service water are connected at various points around the loop. Isolation valves are provided at intervals around the loop that can be used to interrupt the flow and isolate portions of the loop.

Analyses performed utilizing the PBNP SW model demonstrate that with five service water pumps operable, as allowed by TS 15.3.3.1 2.a, the loop header may be interrupted at any one of th isolation valves concurrent with any or all other limiting conditions in TS 15.3.3.D-2 ano still perform its accident mitigation functions.

If only four service water pumps are operable, as allowed by TS 15.3.3.D-2.a, adequate SW flow to required equipment and components can be assured concurrent with the other conditions allowed by TS 15.3.3.D-2 when the loop header flowpath is interrupted between the pump bays at valves SW-2890 and/or SW-2891.

When portions of the loop header are completely isolated from the flowpath, SW flow will be interrupted to those components supplied from the isolated section of the header, while adequate flows are provided to components served by the unisolated section.

Without adequate SW flow, the affected components cannot perform their required l functions and are therefore inoperable. When this occurs, the appropriate limiting conditions for operation for the affected system or equipment are entered and required action taken.

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NPL 98-0613 Attachment 1 Page 3 For some equipment and components, it is possible to realign the component to receive the required SW flow from the unisolated portion of the loop header. When realignment cccurs, the equipment or component is operable and the related LCO exited. Direction to exit is not required in this Specification since the action is governed by the individual equipment Specifications and system procedures where applicable.

Provision b.iii allows evaluation of other loop header and pump configurations as acceptable by this LCO prior to placing the system in that configuration. This provision is consistent with the licensing conditions on Service Water and Component Cooling Water System operation in Appendix C of the Facility Operating Licenses issued with Amendments 174 and 178 for Units 1 and 2, respectively, on July 9,1997. That is, compliance with this provision ensures the system is operated in accordance with approved analyses. Requirements to enter applicable system and equipment LCOs and take required action for any systems and equipment rendered inoperable by the lineup are also applicable to this orovision.

Containment Fan Cooler Outlet Motor Operated Valves In response to a safety injection signal, motor-operated valves at the SW outlet from the containment fan coolers open to increase cooling water flow to the fan coolers. As documented in the Technical Specification basis, when an MOV is open, the opposite unit is in an LCO for service water since a portion of service water flow will be diverted from that unit in the event of a design basis accident. It is proposed that the LCO related to containment fan cooler MOVs be revised as follows:

d. The containment fan cooler outlet motor operated valves may be open for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided the valves are onerable and at least five service water I pumps are operable. This LCO may be exited provided the valves-are returned to the c!csed position er the f!cwpath4vAated:

Basis for Chargq The analysis for this change assumes that nonessential service water flow is isolated prior to the transition to containment sump recirculation and that SW flows to the non-accident unit's fan coolers are normal. Therefore, it is necessary to shut these valve (s), if open, following a design basis accident in the opposite unit. Requiring the valves to be operable when open ensures the valves can be shut as assumed in the analysis.

I The explanation for exiting this LCO is deleted since this is common to the application and usage of the Technical Specifications and required action.

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NI'L 98-0613 Attachment 1 Page 4 Bases Chanees Techn'ical Specification bases changes are being made to reflect the proposed Technical Specification changes.

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NPL 98-0613 Att :nt 2 Pa -

SAFETY EVALUATION TECHNICAL SPECIFICATION CHANGE REOUEST 206 SERVICE WATER SYSTEM OPERABILITY POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 Introduction In accordance with the requirements of 10 CFR 50.4 and 10 CFR 50.90, Wisconsin Electric Power Company (WE) is requesting amendments to Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units 1 and 2, respectively. The purpose of the proposed amendments is to reflect Limiting Conditions for Operation for the Service Water (SW) System, that appropriately control system operation in accordance with approved system analyses.

System Description

The SW system is designed to provide cooling water supplies with isolatian valves to AFW pump bearing cooling, the two Train A emergency diesel generators, air compressors, component cooling heat exchangers, spent fuel pool cooling system, the containment air recirculating cooling system, primary auxiliary building battery room coolers, and nonessential users. The system provides a manually aligned seismic source of water to the AFW system in the event of a loss of the normal AFW suction source from Condensate Storage Tanks.

The system also supplies water for the fire protection sprinkler systems in the Train A emergency diesel generator (G01 and G02) rooms and the containment hose reels. The design includes provisions for automatic isolation of non-essential components following an accident.

Although not specifically identified in the PBNP FSAR Chapter 14 accident analyses, the SW system provides support for the Train A em = Tency diesel generators, auxiliary feedwater system, component cooling water system, PAB battery room coolers and containment air recirculation cooling system for accident mitigation. The spent fuel pool cooling system, air compressors, fire protection system and other nonessential equipment do not provide a Chapter 14 accident mitigation function. Normal alignment, SW function and applicable Technical Specifications for required accident mitigation equipment is provided in Table 1.

The SW system is supplied by six SW pumps, three per emergency power train, taking suction directly from Lake Michigan and discharging to a loop header supplying both units. The loop header is provided with isolation valves that may be used to isolate the north, south, cast and west header sections. Essential loads, except for the containment

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NPL 98-0613 Attachment 2 Page 2 fan coolers (tyvo each unit) supplied by the west header, may be manually aligned to either the north or south header as required. SW system discharge may be aligned to t!.: I circulating water discharge for either PBNP Unit.

The SW pumps discharge to the east header. The east header is provided with redundant motor operated valves which may be used to divide the header between the pump bays into sets of three SW pumps. These valves are used to isolate sections of the pump header or to separate the header as necessary during pump inservice testing to obtain the required pump flows.

SW pumps are sequenced on in response to a safety injection signal as outlined in FSAR Section 8.2. Ifless than four service water pumps start in response to a Safety Injection signal, nonessential users are automatically isolated. Emergency Operating Procedures verify isolation of nonessential users prior to aligning the Residual Heat Removal (RHR)

System (e.g., low head safety injection) for containment sump recirculation.

A detailed description of the SW system is provided in Section 9.6.2 of the FSAR.

System Evaluation Model Engineering analyses for determining flow rates in the SW system are based on the use of a computer model of the SW system. The model is based on software which simulates water distribution systems and predicts steady state flow in pipes. Validation of the PBNP SW system model by comparison of the computer program results with actual plant data and specifications demonstrates that the program can be used to predict flows f in the SW system.

1' The hydraulic model was developed by Wisconsin Electric from the as-built system and is intended to provide reasonable verification of SW system performance.

System Evaluation Four sets of analyses were performed in support of the proposed Tecimical Specifications changes. The first set of runs assumes the SW system is fully operable prior to the design basis accident. One run models the injection phase of the accident, the other models the contaimnent sump recirculation phase of the accident. These analyses demonstrate the ability of the SW System to perform its design basis functions with a single train (3 SW pumps) operating assumiag a worst case single failure which disables one emergency power supply train.

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NPL 98-0613 Attachment 2 Page 3 Key assumptions of these first two evaluations include:

1. Both units are initially operating at 100% power prior to the accident.

2. The limiting accident, a large break Loss of Coolant Accident (LOCA) occurs in one unit. The other unit continues to operate at 100% power. Maintaining a unit at power maximizes the service water demands on the operating unit (minimizes SW availability to the accident unit), and bounds the PBNP design basis of an accident in one unit and maintaining hot shutdown in the non-accident unit.

3. No loss of offsite power (LOOP) occurs. Maintaining offsite power maintains Circulating Water system operatien which minimizes the level in the forebay (the suction source for the SW pumps) tbus minimizing SW pump suction head and discharge pressure.

4. The worst case single failure assumed is the loss of the entire B train of safeguard power in the accident unit. This failure results in the failure of three SW pumps to operate. In addition, the accident unit turbine hall, water treatment and Train B spent fuel pool heat exchanger (nonessential users) fail to isolate due to the Train B power failure. The non-accident unit turbine hall isolation remains open to support continued operation of the unit. All other equipment or component failures as a result of Train B power failure are assumed to occur.

5. All SW pumps are assumed 8% degraded from their nominal pump curves. This is consistent with Inservice Test acceptance criteria. Actual performance of all SW pumps presently exhibit less degradation.

6. All component temperature control valves (TCV) are assumed in the maximum flow operating position due to high service water temperatures. One CCW heat exchanger in each unit is operating on its TCV with both inlet and outlet blowdown valves .open. The second heat exchanger in each unit is modeled with only its inlet and outlet blowdown valves open.

7. For the recirculation phase, non-essential users, Spent Fuel Pool Culing 1 (SW-2930A and SW-2936B), Auxiliary Building Cooling (SW-2816), SW supply to Radwaste (SW-LW-61 or SW=LW-62), Water Treatment (SW-2817) and the affected unit Turbine Hall (l(2)SW-2880), are isolated ifless than 4 SW pumps at:

running. Procedures have been revised to ensure these non-essential users me verified isolated or isolated prior to transferring from injection to containment sump recirculation. Procedures have been validated by walkthroughs to ensure the required isolations can be accomphshed within the time periods reqaired. In l

NPL 98-0613 Attachment 2 Page 4 addition, both CCW heat exchangers are placed into service to support containment sump recirculation.

8. Lake Michigan is assumed at its design basis low level (-4 ft from normal) and maximum assumed temperature (75* F). The calculations also evaluated component operability at higher lake temperatures.

9. Only one main SW zum strainer is assumed to be blowing down at any one time. I The timing circuit for the automatic blowdown feature has been adjusted to maintain this analysis assumption.

10. The condensate storage tanks are the suction source for AFW consistent with q system design and operation. For a design basis LOCA, AFW flow is not necessary to m.Higate the consequences of the accident.

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I 1. Containment Fan Cooler Service Water outlet motor operated valves (MOVs) that I may be open in the nonaccident unit are shut prior to the accident unit transitioning to containment sump recirculation. ]

12. Each unit has two Containment Fan Cooler Service Water outlet MOVs. Only one )

is required to open to ensure sufEcient SW flow to the fan coolers for accident mitigation. Analyses were performed with one and with both MOVs opening to ensure bounding cases for flow and system pressure, respectively were considered. I

13. Other loads supplied by SW are in their normal lineups.

Evaluations were also performed for the injection phase and recirculation phase of a LOCA to determine the acceptable limiting conditions of operation for the SW system.

The initial assumptions for these evaluations are identical to the assumptions above with the following modifications and additional assumptions. .

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1. When in a Limiting Condition for Operation, no additional system or equipment )

failures are assumed concurrent with the accident. l l

2. Any or all SW pump, valve and header LCOs may be in effect at the same time subject to the limitations specified in the LCO.

3. Any time the loop header continuous flow path is interrupted, a minimum of five SW pumps are assumed to be operable except if the flowpath is interrupted between the pump bays or at a west header valve location (SW-2890 and/or SW-2891, or SW-2869 or SW-2870) when four service water pumps are assumed to be operable.

This latter configuration, interruption at SW-2890 and/or SW-2891, is required to

NPL 98-0613 Attachment 2 Page 5 support testing of the SW pumps. Interruption at SW-2869 or SW-2870 was also I verified to be acceptable in the analyses.

4. Radwaste processing, accident unit Turbine Hall and Water Treatment nonessential service ' vater users are isolated prior to transitioning to containment sump recirculation ifless than five service water pumps are running or the service water I ring header continuous flow path is interrupted (at least one header isolation valve shut). This isolation is accomplished by procedure even ifinoperable for automatic isolation.

Evaluation Results The results of these evaluations demonstrate that all systems and equipment supported by ,

Service Water necessary to respond to and mitigate the consequences of the design basis

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accident (LOCA) perform their functions as descr^ed in the FSAR subject to the j limitations of the analysis assuraptions. This conclusion is based on the following l evaluation results:

. Analyses demonstrate that adequate flow exists to all required safety-related components to ensure the safety function is accoroplished.

. Accident unit Containment Fan Coolers remove the design basis heat load for a maximum SW inlet temperature of 75 F and a range of cooler fouling factors of 0.0003 to 0.0017. Analyses results demonstrate that at the minimum fouling factor (maximum heat transfer) boiling does not occur at the outlet to the fan coolers as required by the FSAR and design basis heat removal requirements are met for the assumed range of fouling.

. No boiling of SW occurs in the CFCs under steady state conditions as required by the PBNP design and licensing basis.

Procedure changes have been made to ensure the analysis assumptions remain valid.

Thus the SW system is considered operable when operated within the bounds of these analyses.

Pronosed Technical Specifications Chances Changes are propos::d to Technical Specifications 15.3.3.D-2 consistent with the above assumptions. These changes provide assurance that the SW system performs the required support functions for equipment necessary to mitigate the consequences of accidents as described in the FSAR.

l Technical Specification 15.3.3.D-2.b provides for up to seven days inoperability of the SW header continuous flow path. The Specification, as proposed, provides for I

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NPL 98-0613 Attachment 2 Page 6 interruption of the flowpath anywhere in the loop header provided five service water pumps are operable. For interruption between the pumps bays only, four service water pumps are required to be operable. All accident mitigation functions are supported for these system lineup as demonstrated by the flow evaluations performed. These conditions are mere restrictive than the existing Specifications.

In the proposed four service water pump header alignment, the allowed time in this configuration is effectively limited by Technical Specifications 15.3.3.D-2.a.

TS 15.3.3.D-2.a limits operation with two or three SW pumps inoperable to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Proposed TS 15.3.3.D-2.b allows evaluation of other SW pump and loop header alignments prior to placing the system in that configuration. An acceptable evaluation is one that demonstrates that required systems and components supported by SW are operable, or identifies inoperable systems and components to ensure that a condition prohibited by specific system and component Technical Specifications does not result.

As indicated above, operation in these other alignments is effectively limited by TS 15.3.3.D-2.a for the SW pumps. This allowed outage time is consistent with PBNP Technical Specifications for other accident mitigation equipment.

This analysis requirement is consistent with, but more restrictive than the present requirement contained in existing Specification 15.3.3.D-2.b. The existing requirement allows up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following entry into the condition to perform such an evaluation.

By requiring the evaluation to be completed prior to placing the system in the desired lineup, additional assurance is provided that the SW system remains operable. This !

stipulation is consistent with license conditions added to the PBNP Facility Operating Licenses with Amendments 174 and 178 for Units 1 and 2 respectively, issued on July 9, 1997. These license conditions require the SW system to be operated in accordance with the system analyses except for short periods of time as necessary to effect procedurally controlled changes in system lineups and Unit operating conditions. This stipulation provides some flexibility recognizing that evaluations of other operating conditions will continue and will support further improvements of analpis tools.

Proposed TS 15.3.3.D-2.b retains the direction requirind entry into applicable system and equipment LCO if equipment is rendered inoperable d ae to the Sersice Water System header and pump configuration (due principally to the loss of SW flow to support the system or equipment operation). This requirement ensures that the safety significance of the inoperable equipment is appropriately accounted '.or in the time allowed in the configuration. In general, for accident mitigation Fjstems, time is limited to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . l A statement that the LCO can be exited if sys tem realignment is perfomied to regain required flows to the affected systems or equ pment is being removed as this condition is 1

NPL 98-0613 Attachment 2 Page 7 unnecessary. This direction is not necessary since demonstration of operability is necessary for exiting any LCO consistent with standard Technical Specification usage. ;

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The final proposed change to Technical Specification 15.3.3.D-2 is to add the

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requirement that if the containment fan cooler outlet motor operated valves are open that j they be operable. As discussed in the bases, opening of the outlet valve in one unit, places the other unit into this LCO since a portion of the SW flow is diverted from that !

unit in the event of an accident. The analyses performed assumes that these valves are )

shut in the opposite unit prior to the accident unit transition to containment sump recirculation mode oflong-term cooling. Requiring the valves to be operable ensures that the valves can be shut, thus supporting the assumptions in the analyses.

Conclusion j Analyses have been performed utilizing the Service Water System model for the Point Beach Nuclear Plant. The limiting assumptions in the analyses on SW System and component operation are being incorporated into plant operating and emergency

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procedures. These assumptions have also been translated into the Technical Specifications to ensure the Specifications provide appropriate controls on system alignments and limits on equipment operability. These co " mis and limits provide a high 4 degree of confidence that the SW System will perform i: (m A s as designed and analyzed consistent with the systems overall importance . % ' ay. 3 I

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NPL 98-0613 Attachment 2 Page 8 Table 1 Technical Specification Eq~uipment Supported by Service Water EQUIPMENT SERVICE WATER SUPPORT SERVICE WATER SUPPLY APPLICABLE TECHNICAL FUNCTION SPECIFICATIONS SECTIONS G-01 Emergency Diesel Engine cooling water Normally South header. LCO 615.3.7 Generator Train A supply. North header alternate SURVEILLANCE $15.4.6 (SHARED) supply.

G-02 Emergency Diesel Engine cooting water Normally North header. LCO $15.3.7 Generator Train A supply. South header alternate SURVEILLANCE 615.4.6 (SHARED) supply.

1P 29 Unit 1 Turbine Bearing cooling and Norms'1, DJth header. LCO 615.3.4 driven AFW Pump alternate suction source. S.ch header alternate SURVEILLANCE 115.4.8 iupply. !

P 38A Train A Electric Bearing cooling and Nermally South header. LCO 615.3.4 motor driven AFW Pump alternate suction source North header alternate SURVEILLANCE 515.4.8 (SHARED) suppt/.

P-388 Train B Electric Bearing cooling and Normally North header. LCU 615.3.4 motor driven AFW Punp alternate suction source. South header alternate SURVEILLANCE 515.4.8 (SHARED) supply.

2P 29 Unit 2 Turbine Bearing cooling and Normally North header. LCO 615.3.4 Driven AFW Pump alternate suction source. South header alternate SURVEILLANCE 615.4.8 supply.

HX 12A and HX-12B CCW Cooling water for heat Normally South header., LCO 615.3.3 Heat Exchangers exchanger operation. North header alternate SURVEILLANCE NONE (SHARED) supply.

HX-12C and HX-120 CCW Cooling water for heat Normally North header. LCO 615.3.3 Heat Exchangers exchanger operation. South hee. der alternate SURVEILLANCE NONE (SHARED? supply.

1W-101 and 1W 101 Unit 1 Cooling water for heat South Header LCO 115.3.3 Containment Fan Cooler exchanger operation and SURVE!LLANCE 115.4.5 Units and associated Heat f an motor cooling.

Exchangers 1W-1A1 and 1W-1C1 Unit 1 Cooling water for heat West Header LCO 615.3.3 Containment Fan Cooler exchanger operation and SURVEILLANCE 115.4.5 Units and associated Heat fan motor cooling.

Exchangers 2W-181 and 2W-101 Unit 2 Cooling water for heat North Header ]

LCO 615.3.3 l Containment Fan Cooler exchanger operation and SURVEILLANCE 615.4.5 Units and associated Heat fan motor cooling.

Exchangers 2W-1A1 and 2W-1C1 Unit 2 Cooling water for heat West Header LCO 115.3.3 J Containment Fan Cooler exchanger operation and SURVEILLANCE 115.4.5 j Units and associated Heat fan motor cooling. j Exchangers i I 4

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NPL 98-0613 Attachment 3 Page1 NO SIGNIFICANT HAZARDS CONSIDERATION TECHNICAL SPECIFICATIONS CHANGE REOUEST 206 SERVICE WATER SYSTEM OPERABILITY POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 In accordance with the requirements of 10 CFR 50.4 and 10 CFR 50.90, Wisconsin Electric Power Company (WE) is requesting amendments to Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units 1 and 2, respectively. The purpose of the proposed amendments is to reflect Limiting Conditions for Operation for the Service Water (SW) System, that appropriately control system operation in accordance with approved system analyses.

Wisconsin Electric has evaluated the proposed amendments in accordance with 10 CFR 50.91 against the standards in 10 CFR 50.92 and has determined that the operation of the Point Beach Nuclear Plant in accordance with the proposed amendments presents no significant hazards. Our evaluation against each of the criteria in 10 CFR 50.92 follows.

1. Operation of the Point Beach Nuclear Plant in accordance with the proposed amendment does not result in a significant increase in the probability or consequences of any accident previously evaluated. !

The Service Water System is primarily a support system for systems required to be operable for accident mitigation. Portions of the SW system supplying the containment fan coolers also function as part of the containment pressure boundary under post accident conditions. Failures within the SW system are not an initiating j condition for any analyzed accident. {

l Analyses performed demonstrate that under the Technical Specifications allowable i configurations, the SW system will continue to perform all required functions. The I SW system is capable of supplying the required cooling water flow to systems )

required for accident mitigation. Th.c is, the SW system removes the required heat I from the containment fan coolers and residual heat removal heat exchangers ensuring {'

containment pressure and tempermure profiles following an accident are as evaluated in the FSAR. This in turn ensures that environmental qualification of equipment inside containment is maintained and thus function as required post-accident.

SW system resporise post accident is within all design limits for the system.

l Transient and steady state forces within the system remain within all design and l operability limits thereby maintaining the integrity of the system inside containment and the integrity of the containment pressure boundary. Assumptions dependent on 1

NPL 98-0613 Attachment 3 Page 2 containment pressure profile for containment leakage assumed in the radiological consequence analyses remain valid.

In addition, removing required heat from containment ensures that cooling of the reactor core is accomplished for long-tenn accident mitigation.

Therefore, operation ofthe SW system as proposed will not result in a significant increase in the probability or consequences of any accident previously evaluated.

2. Operation of the Point Beach Nuclear Plant in accordance with the proposed amendments does not result in a new or different kind of accident from any accident previously evaluated.

The proposed changes do not alter the way in which the SW system performs its design functions nor the design limits of the system. The proposed changes do not introduce any new or different normal operation or accident mitigation functions for the system. Therefore, no new accident initiators are introduced by the proposed changes. Operation of SW system as proposed cannot result in a new or different kind of accident from any accident previously evaluated.

3. Operation of the Point Beach Nuclear Plant in accordance with the proposed amenrlments does not result in a significant reduction in a mr, gin of safety.

Analyses performed in support of the proposed amendments J ;monstrate that the SW system continues to perfomiits function as assumed an'. credited in the accident analyses and radiological consequence analyses performed or the Point Deach Nuclear Plant. Therefore, the analyses and results are not changed. All analysis limits remain met. The SW system continues to be operated and responds within all design limits for the system. Therefore, operation of the Peint Beach Nuclear Plant in accordance with the proposed amendments cannot result in a reduction in a margin of safety.

Conclusion Operation of the Point Beach Nuclear Plant in accordance with the proposed amendments will not result in a significant increase in the probability or consequences of any accident previously analyzed; will not result in a new or different kind of accident from any accident previously analyzed; and, does not result in a reduction in any margin of safety.

l Therefore, operation of PBNP in accord.aice with the proposed amendments does not l result in significant hazards determination.

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l Wisconsin Electnc POWER COMPANY l

Point Beach Nuclear Plant (920) 755-2321 l 6610 Nuclear Rd., Two Rivers. WI 54241 NPL 98-0613 July 30,1998 Document Control Desk U.S. NUCLEAR REGULATORY COMMISSION Mail Station Pl-137 Washington, DC 20555 Ladies / Gentlemen:

l DOCKETS 50-266 AND 50-301 TECHNICAL SPECIFICATIONS CH ANGE REOUEST 206 SERVICE WATER SYSTEM OPERABILITY

POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 In accordance with the requirements of 10 CFR 50.4 and 10 CFR 50.90, Wisconsin Electric l Power Company (licensee) hereby requests amendments to facility operating licenses DPR-24 and DPR-27, for Point Beach Nuclear Plant, Units 1 and 2, respectively. The purpose of the proposed amendments is to incorporate changes to the Technical Specifications to more clearly l define the requirements for Service Water System operability.